Estate of James T. Campion, Deceased, Leona Campion, Executrix, et al. - Page 2

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                    Petitioners (investors in the so-called Elektra                   
               Hemisphere tax shelters) move for leave to file motions                
               under Rule 162 to vacate final decisions that have been                
               entered herein and to require respondent now to enter                  
               into revised settlement agreements with petitioners                    
               (that reflect settlement terms available from                          
               respondent to investors in 1986, 1987, and 1988).                      
               Held:  Petitioners’ motions are denied.                                


               Declan J. O'Donnell, for petitioners.                                  
               Michael W. Bitner, for respondent.                                     


                                       OPINION                                        

               SWIFT, Judge:  This matter is before the Court in these                
          consolidated cases on petitioners’ motions for leave to file                
          motions to vacate decisions with attached motions to vacate under           
          Rule 162.                                                                   
               Unless otherwise indicated, all Rule references are to the             
          Tax Court Rules of Practice and Procedure, and all section                  
          references are to the Internal Revenue Code for the years in                
          issue.                                                                      
               In each of these cases, petitioners and respondent settled             
          all issues, and final decisions have been entered.  The 90-day              
          appeal period has expired, and petitioners now seek orders from             
          the Court vacating the decisions and requiring respondent to                
          enter into new settlement agreements with petitioners that would            




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