MEMORANDUM OPINION
LARO, Judge:
Esmat A. and Sylvia Zaklama move the Court to grant leave to file a motion to vacate our order dismissing their case for lack of jurisdiction. The motion for leave will be denied. Unless otherwise noted, section references are to the Internal Revenue Code applicable to the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.
Background
Respondent determined a $101...
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