- 13 - In an order dated April 11, 1997, the Court directed respondent to file a response to petitioners' motion, while allowing Robert Patrick Sticht, Esq. (Mr. Sticht), counsel for non-test-case taxpayers participating in the Dixon evidentiary hearing, and Joe Alfred Izen, Jr., Esq. (Mr. Izen), counsel for test-case and non-test-case taxpayers participating in the Dixon evidentiary hearing, to file a response to petitioners' motion in their discretion. On May 12, 1997, respondent filed a response in opposition to petitioners' Motion for Reconsideration with attached Motion To Consolidate. On May 30, 1997, pursuant to the Court’s order dated April 11, 1997, Mr. Sticht filed a response in opposition to petitioners' motion insofar as petitioners seek to have their case consolidated with the Dixon group of cases. Mr. Izen did not file a response to petitioners' motion. Discussion 1. Petitioners' Motion for Leave To File Motion To Vacate Decision Section 7481(a)(1) provides the general rule that a decision of the Tax Court becomes final upon expiration of the time to file a notice of appeal. Section 7483 provides that a notice of appeal generally must be filed within 90 days after a decision is entered. However, the 90-day appeal period may be extended ifPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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