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accepted an offer that was essentially the same as the Plastics
Recycling project settlement offer that petitioners failed to
accept prior to trial. Petitioners' motions are not supported by
the principle of equality on which they rely. Cf. Baratelli v.
Commissioner, T.C. Memo. 1994-484.
To reflect the foregoing,
Appropriate orders will be
issued denying petitioners'
motions, and decisions will be
entered under Rule 155.
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