- 91 -- 91 -
petitioners failed to accept prior to trial. Accordingly,
petitioners' motions are not supported by the principle of
equality on which they rely. Cf. Baratelli v. Commissioner, T.C.
Memo. 1994-484.
In order to reflect the foregoing,
An appropriate order will
be issued denying petitioners'
motions, and decisions will be
entered under Rule 155.
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