MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge.
This case is before the Court on petitioners' motion for leave to file out of time a motion for reconsideration of opinion (motion for leave) and petitioners' motion for reconsideration of opinion and memorandum brief in support thereof (motion for reconsideration) regarding our opinion in Rinehart v. Commissioner [Dec. 54,684(M)],
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