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CARPENTER v. COMMISSIONER

Docket No. 23735-94.

75 T.C.M. 1869 (1998)

T.C. Memo. 1998-81

Bruce L. Carpenter and Carolyn L. Carpenter v. Commissioner.

United States Tax Court.

Filed February 25, 1998.

Attorney(s) appearing for the Case

Alan R. Herson, Medford, Ore., for the petitioners. Gerald W. Douglas, for the respondent.

MEMORANDUM OPINION

CHIECHI, Judge:

This case is before the Court on petitioners' motion for leave to file a motion to vacate decision out of time embodying petitioners' motion to vacate decision (petitioners' motion). Respondent filed a response to petitioners' motion in which respondent objects to the granting of that motion. We shall deny petitioners' motion.

Background

On September 23, 1994, respondent issued a notice of deficiency...

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