John M. Mekulsia - Page 13

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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 L. 101-239, sec. 7721(b), 103 Stat. 2399, repealed sec.                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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