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
Procedure.
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