- 3 -
(1) Whether we should exercise our discretion and grant
petitioners' Motion for Leave (and thereby file petitioners'
Motion to Vacate); and, if so,
(2) whether we should grant petitioners' Motion to Vacate.3
Neither party requested an evidentiary hearing, and the
Court concludes that such a hearing is not necessary for the
proper disposition of petitioners' Motion for Leave and Motion to
Vacate. We therefore decide the matter before us based on the
record that has been developed to date.
Petitioners' principal place of business was in San Diego,
California, at the time that the petition was filed with the
Court.
Background
In June 1992, respondent sent petitioners a notice of
deficiency. In the notice, respondent determined the following
deficiency and additions to tax in petitioners' consolidated
income tax for the taxable year ended March 31, 1986:
Additions to tax
Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661(a)
$14,458,059 $722,903 1 $3,614,515
1 50% of the interest due on $14,458,059.
3 Although only petitioner's Motion for Leave is presently
before the Court, petitioners' Motion to Vacate is essentially
identical to petitioners' Motion for Leave.
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