OPINION
NIMS, Chief Judge:
This matter is before the Court on petitioners' motion for leave to file first amended petition. (All Rule references are to the Tax Court Rules of Practice and Procedure.)
Petitioners timely filed a petition with this Court contesting respondent's deficiency determinations for 1977 and 1978 as well as raising claims that provide the basis of an overpayment, to which respondent filed a timely answer. Petitioners...
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