Esmat A. Zaklama and Sylvia Zaklama - Page 6

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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             
               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                 
               To reflect the foregoing,                                              
                                                  An appropriate order                
                                             will be issued.                          

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