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an Order dated December 4, 1996, the Court granted respondent's
motion and extended the date for respondent to file an objection
to January 6, 1997.10 On January 6, 1997, the Court filed
respondent's Response in opposition to petitioners' motion for
leave.
On March 24, 1997, the Court filed its Memorandum Opinion,
Richards v. Commissioner, T.C. Memo. 1997-149 (Richards I),
rejecting petitioners' Scar argument and denying petitioners'
motion for leave. Mr. Jones subsequently was served with the
Court's Memorandum Opinion as well as respondent's Response to
petitioners' motion for leave.
On April 9, 1997, the Court filed petitioners' Motion for
Reconsideration with attached Motion To Consolidate and
petitioners' Memorandum of Points and Authorities. Petitioners
contend that the Court should reconsider its denial of
petitioners' motion for leave on the grounds that the Court
“misinterpreted” petitioners' Motion To Vacate Decision, and the
Court incorrectly denied petitioners' motion for leave without
first allowing petitioners to file their Motion To Vacate
Decision, conduct necessary discovery, and have a hearing.
Petitioners maintain that the Court misinterpreted their
Motion To Vacate Decision insofar as the Court treated the motion
10 The Court's Dec. 4, 1996, Order expressly directed that
the Order be served on Mr. Jones.
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