James G. & Katherine Bourekis - Page 6

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          interest should be abated for 1981.  Petitioners assert that they           
          requested that respondent abate interest during settlement                  
          conferences with respondent and that the Court should treat the             
          notice of deficiency as respondent's "final determination" not to           
          abate interest.                                                             
               This matter was called for hearing at the Court's motions              
          session in Washington, D.C.  Counsel for respondent appeared at             
          the hearing and presented argument in support of the pending                
          motion.  Further, respondent stated that, at the time of the                
          hearing, petitioners were not precluded from filing a request for           
          abatement of interest.  Although petitioners did not appear at              
          the hearing, they did file a written statement with the Court               
          pursuant to Rule 50(c).  Petitioners' Rule 50(c) statement                  
          includes allegations that the Court should treat the notice of              
          deficiency in this case as respondent's final determination to              
          deny petitioners' request to abate interest in light of                     
          respondent's final determination denying a request for abatement            
          of interest filed by T. John Tsalaky, petitioner James Bourekis'            
          brother-in-law and partner in PCS. (T. John and Magdaline B.                
          Tsalaky filed a petition for review of respondent's denial of               
          their request to abate interest.  That matter is currently                  
          pending before the Court at docket No. 7012-97.)  Petitioners               
          contend that, under the circumstances, it would be "futile,                 

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