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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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