Mark A. and Juanita D. Murdock - Page 4

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            agreed to the following deficiencies in Federal income taxes and                           
            additions to tax:                                                                          

                   Additions to Tax                                                                    
            Sec.         Sec.       Sec.                                                               
            Year     Deficiency      6653(b)       6661       6663                                     
            1988       $3,115        $2,336         -0-        --                                      
            1989          924           693         --         -0-                                     

                  The decision document was forwarded to the Court, and the                            
            decision was entered on January 11, 1994.  At the ensuing trial                            
            session at Detroit on January 31, 1994, the case was not called,                           
            nor did petitioners or their attorney appear for trial.                                    
            Petitioners were thereafter assessed by respondent for income tax                          
            deficiencies and additions to tax in accordance with the                                   
            decision.  It appears that no collection was made on the assessed                          
            liabilities until petitioners filed their 1994 Federal income tax                          
            return.  That return reflected an overpayment of 1994 taxes in                             
            the amount of $1,727.  In lieu of refunding the overpayment to                             
            petitioners, respondent applied the $1,727 to petitioners' unpaid                          
            1988 liability.  That action by respondent gave rise to the                                
            motion presently before the Court.                                                         
                  In their motion for leave to file, in which petitioners are                          
            pro se, petitioners contend there was fraud on the Court and on                            
            the Internal Revenue Service (IRS) in the stipulated decision                              
            that was signed by their attorney and counsel for respondent on                            
            January 5, 1994.  Petitioners correctly allege that they did not                           




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