-9-
certain concessions by both parties: Total deficiencies for the
7 years at issue were reduced by $568,259 ($219,723 in the
stipulated decision versus $787,982 in the notice of deficiency),
and additions to tax for negligence were substituted for the
civil fraud penalty, resulting in a further reduction of over
$300,000 in petitioners’ tax liability as determined in the
Gazis’ notice of deficiency. On July 8, 2003, the Court entered
its decision in docket No. 7950-98 pursuant to the stipulation.
No notice of appeal or timely motion to vacate or revise the
decision having been filed in this case, the decision in docket
No. 7950-98 became final on October 6, 2003. See sec.
7481(a)(1); Fed. R. App. P. 13(a).
On March 12, 2004, petitioners filed motions for leave to
file motions to vacate final decisions in these cases, lodging
therewith their motions to vacate. The motions were signed by
Caroline D. Ciraolo, who on the same date filed entries of
appearance in these cases. Also on the same date, petitioners
filed motions to withdraw Mr. Kauffman as counsel in these cases.
On December 15, 2004, the Court held an evidentiary hearing
in Washington, D.C., with respect to the motions.6 At the
commencement of the hearing, the Court granted petitioners’
motions to withdraw Mr. Kauffman as counsel. At the conclusion
6 The hearing was delayed in part at the request of
petitioners’ new counsel because of her pregnancy.
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