ORDER
SHUBB, District Judge.
In 1985, appellant, Universal Life Church ("ULC"), filed a petition in the tax court seeking redetermination of income tax deficiencies for the 1978, 1979, and 1980 tax years. Over a three year period, the trial date was continued four times, finally resulting in a December 4, 1989, trial date. On November 24, 1989, less than two weeks before the start of trial, ULC filed a motion seeking to amend its petition to permit the use...
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