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YUE v. COMMISSIONER

Docket No. 24414-87.

67 T.C.M. 2161 (1994)

T.C. Memo. 1994-57

David D. and Tienjen Yue v. Commissioner.

United States Tax Court.

Filed February 14, 1994.

Attorney(s) appearing for the Case

David D. and Tienjen Yue, pro se. John P. Jankowski, for the respondent.

Memorandum Opinion

POWELL, Special Trial Judge:

This case is before the Court on petitioner's Motion for Leave to File Motion to Vacate Out of Time, filed on January 24, 1994. The facts, as alleged in the motion or as otherwise shown in the record, are as follows.

By a notice of deficiency dated April 15, 1987, respondent determined deficiencies and additions to tax were due from petitioners for the taxable...

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