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time a motion to vacate; (2) a motion for leave to file out of
time a motion for reconsideration of findings of fact and
opinion; and (3) a request for a rehearing. On February 4, 1997,
the Court granted both of the motions and the request.
On July 14, 1997, the Court denied (1) the motion to vacate,
(2) the motion for reconsideration of findings of fact and
opinion, and (3) the request for a rehearing.
F. Assessment of Income Tax and Computation of Interest
On February 27, 1998, respondent sent petitioner a Form
4549A-CG, Income Tax Examination Changes, for each of the tax
years 1982 through 1987. For each of those tax years, the form
and attached explanations detailed the adjustments made to
petitioner’s individual tax returns and calculated the
deficiencies in each year’s income tax. In addition, the
explanations for each year informed petitioner that respondent
had determined that a part of his underpayment of tax was
attributable to tax-motivated transactions as defined in section
6621(c).6 The 1982 through 1987 adjustments made to petitioner’s
tax returns were based on his participation in SGE during the
6 The Omnibus Budget Reconciliation Act of 1989 (OBRA),
Pub. L. 101-239, sec. 7721(b), 103 Stat. 2399, repealed sec.
6621(c). This repeal was effective for returns the due date for
which (determined without extensions) is after Dec. 31, 1989.
See OBRA sec. 7721(c), 103 Stat. 2400.
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