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CUTAIA v. COMMISSIONER

Docket No. 10742-95.

74 T.C.M. 1261 (1997)

T.C. Memo. 1997-527

Anthony F. Cutaia and Susan D. Cutaia v. Commissioner.

United States Tax Court.

Filed November 24, 1997.

Attorney(s) appearing for the Case

Richard J. Rothman, Jeffrey H. Pasternak, Great Neck, N.Y., and Gilbert T. Perlman, for the petitioners. Drita Tonuzi, Henry S. Schneiderman, and Roland Barral, for the respondent.

MEMORANDUM OPINION

CHIECHI, Judge:

This case is before the Court on petitioners' motion for leave to file motion to vacate decision and enter revised decision (petitioners' motion). Respondent filed an objection to the granting of petitioners' motion and an affidavit setting forth facts in support of that objection (respondent's objection). We shall deny petitioners' motion.

Background

On March 16, 1995, respondent issued a notice...

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