OPINION
COLVIN, Judge:
This matter is before the Court on petitioner's motion to stay proceedings. In the motion, petitioner asks the Court to postpone entry of decision until either: (1) An extension of time to pay petitioner's Federal estate tax under section 6161(a) is no longer in effect and any appeal of respondent's denial of an extension is final, or (2) petitioner fully pays its outstanding Federal tax liability and related interest, whichever...
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