- 76 -
Recycling project settlement offer rejected by petitioners prior
to trial. Accordingly, petitioners' motion is 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'
motion, and decisions will be
entered under Rule 155.
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