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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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