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order dismissing Karin M. Locke for lack of jurisdiction in
conformity with the Mandate of the Court of Appeals for the
Second Circuit. The decision of this Court became final on April
23, 2003. See sec. 7481(a)(3)(B).
On December 9, 2003, a Motion for Leave to File Notice of
Election to Participate Out of Time (motion for leave) was filed
on behalf of movant. The motion alleges that movant is a partner
in the Cinema ‘84 partnership and requests that he be appointed
the tax matters partner for the partnership. With the motion,
movant lodged with the Court a motion to vacate order of
dismissal and decision and a motion to be appointed tax matters
partner.
The raison d’�tre of movant’s motion for leave is to have
the Court vacate its decision entered September 1, 2000, that
sustained respondent’s determinations with regard to the taxable
years 1985, 1986, 1987, 1988, and 1989 of Cinema ‘84. In
resolving the question whether leave should be granted, we must
first decide whether the Court’s decision should be vacated.
That decision was entered September 1, 2000, and modified on
March 24, 2003, pursuant to the Mandate of the Court of Appeals
for the Second Circuit. With respect to all the partners who had
not previously settled, with the exception of Karin M. Locke, the
Court’s decision was affirmed by the Court of Appeals for the
Second Circuit and is final.
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