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Zimmerman v. Commissioner, 105 T.C. 220 (1995). Petitioners have
not explained why they did not avail themselves of any of these
opportunities.
We will deny petitioners' motion to file their motion to
vacate out of time. In so doing, we have considered all of
petitioners' arguments for a contrary result, and, to the extent
not addressed above, have found them to be without merit or
irrelevant.
To reflect the foregoing,
An appropriate order
will be issued.
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