MEMORANDUM OPINION
WRIGHT, Judge:
This matter is before the Court on respondent's motion for order to show cause why judgment should not be entered against petitioners on the basis of a previously decided case. Respondent filed her above-referenced motion in the instant case with respect to the disallowance of deductions, investment tax credits, and related additions to tax in connection with petitioners' participation in a tax shelter entitled the Encore...
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