Mark Friedman - Page 5

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               Long after the trials of these cases, petitioners each filed           
          a 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.  These                  
          motions were filed with attached exhibits on October 20, 1995, in           
          the Friedman case, and on November 13, 1995, in the Alter case.             
          On those same dates, petitioners each also lodged with the Court            
          a motion for decision ordering relief from the additions to tax             
          for negligence and the increased rate of interest, with                     
          attachments, and a memorandum in support of the motion.                     
          Subsequently, respondent filed objections, with attachments, and            
          memoranda in support thereof, and petitioners thereafter filed              
          reply memoranda.  For reasons discussed in more detail at the end           
          of this opinion, and also in Farrell v. Commissioner, T.C. Memo.            
          1996-295, these motions shall be denied.  See also Gollin v.                
          Commissioner, T.C. Memo. 1996-454; Grelsamer v. Commissioner,               
          T.C. Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398.           
               The issues remaining in these consolidated cases are:  (1)             
          Whether petitioners are liable for the additions to tax for                 
          negligence under section 6653(a)(1) and (2); and (2) whether                
          petitioners are liable for additions to tax under section 6659              
          for underpayments of tax attributable to valuation                          
          overstatements.                                                             








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