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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 September 22, 1995,
in docket No. 30317-91 (Morgan), and on October 18, 1995, in
docket No. 5788-90 (Grelsamer). On those same dates, petitioners
each 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
such motion. Subsequently, respondent filed objections, with
attachments, and memoranda in support thereof, and petitioners
lodged 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, petitioners' motions shall be denied; see
also Zenkel v. Commissioner, T.C. Memo. 1996-398.
The issues remaining in these consolidated cases are: (1)
Whether petitioners are liable for additions to tax for
negligence under the provisions of section 6653(a); and (2)
whether petitioners are liable for additions to tax under section
6659 for underpayments of tax attributable to valuation
overstatement.
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