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FARRELL v. COMMISSIONER

Docket No. 28082-89.

71 T.C.M. 3218 (1996)

T.C. Memo. 1996-295

Vincent and Clotilde Farrell, Jr. v. Commissioner.

United States Tax Court.

Filed June 25, 1996.

Attorney(s) appearing for the Case

Hugh Janow, for the petitioners. Barry J. Laterman, for the respondent.

MEMORANDUM OPINION

WOLFE, Special Trial Judge:

This matter is before the Court on petitioners' Motion For Leave to File Motion for Decision Ordering Relief From the Negligence Penalty and the Penalty Rate of Interest and to File Supporting Memorandum of Law under Rule 50.1 Petitioners' motion for leave was filed with attached exhibits on November 9, 1995. On the same date, petitioners' motion for decision ordering relief from...

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