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. By order dated August 24, 1994, we granted respondent's motion and ordered petitioners to show cause why judgment should not be entered against them on the basis of the Court's decisions in Wolf v. Commissioner [Dec. 47,341(M)],
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