Philippe and Nadine Grelsamer - Page 6

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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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