Vincent and Clotilde Farrell, Jr. - Page 1

                                 T.C. Memo. 1996-295                                  

                               UNITED STATES TAX COURT                                

                  VINCENT AND CLOTILDE FARRELL, JR., Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 28082-89.                    Filed June 25, 1996.           

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

          1    All section references are to the Internal Revenue Code in             
          effect for the year at issue, unless otherwise indicated.  All              
          Rule references are to the Tax Court Rules of Practice and                  

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