Transpac Drilling Venture 1982-08, Albert D. & Luella L. Eshelman, A Partner Other Than The Tax Matters Partner - Page 1

                                 T.C. Memo. 1996-344                                  


                               UNITED STATES TAX COURT                                

          TRANSPAC DRILLING VENTURE 1982-08, ALBERT D. & LUELLA L.                    
          ESHELMAN, A PARTNER OTHER THAN THE TAX MATTERS PARTNER,                     
          Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent                 

          Docket No. 18511-90.                   Filed July 30, 1996.                 

          Charles Haydon, for petitioners.                                            
          William A. Heard III, for respondent.                                       

                                 MEMORANDUM OPINION                                   

          ARMEN, Special Trial Judge:  This matter is before the Court                
          on participating partner Milton Chwasky's Motion for Leave to               
          File Motion to Vacate Decision filed pursuant to Rule 162.1                 
               The issue for decision is whether grounds exist in this case           
          for vacating what is otherwise a final decision.                            

          1 Unless otherwise indicated, all section references are to                 
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       




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