All Community Walk In Clinic - Page 2

                                         -2-                                          
                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               THORNTON, Judge:  This matter is before the Court on                   
          petitioners’ motions for leave to file motions to vacate the                
          final decisions of this Court, which were entered July 8, 2003              
          (the motions).2  Petitioners contend that the decisions resulted            
          from perpetration of fraud on the Court by their former counsel,            
          Jay E. Kauffman (Mr. Kauffman), and respondent’s counsel, Monica            
          J. Miller (Ms. Miller), in entering into allegedly unauthorized             
          settlement agreements.  Respondent disagrees and objects to the             
          motions.                                                                    
                               Procedural Background                                  
               On January 30, 1998, respondent issued a notice of deficiency          
          with respect to Mohammed A. and Raees I. Gazi (the Gazis), and a            
          separate notice of deficiency with respect to Mrs. Gazi’s wholly            
          owned corporation, All Community Walk In Clinic.3  With respect to          
          the Gazis, respondent determined increases in tax liabilities for           
          tax years 1983 to 1989 totaling $787,982; respondent also asserted          
          civil fraud penalties totaling about $500,000.  With respect to             
          All Community Walk In Clinic, respondent determined increases in            
          tax liabilities for tax years 1983 to 1989 totaling $341,043, plus          


               2 Due to an identity of issues presented by the motions                
          before the Court, the cases at docket Nos. 7949-98 and 7950-98              
          have been consolidated herewith for the purpose of this opinion.            
               3 Raees I. Gazi died on July 23, 2003, after the decisions             
          had been entered in these cases.                                            





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