The Manchester Group and Subsidiaries, Formerly Torrey Enterprises, Inc., and Subsidiaries, Formerly Torrey Development Corporation and Subsidiaries - Page 3

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               (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                
               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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