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Opinion). All Cmty. Walk In Clinic v. Commissioner, T.C. Memo.
2005-190.5 In that Opinion, the Court rejected Mr. Gazi’s argu-
ment that the Gazis’ Tax Court decision resulted from the perpe-
tration of fraud on the Court by Mr. Kauffman and counsel for the
Commissioner. Id. Pursuant to the July 28, 2005 Opinion, on
July 28, 2005, the Court issued an Order denying the motion for
leave to file a motion to vacate final decision in the Gazis’ Tax
Court case.
On August 1, 2005, Ms. Ciraolo and the revenue officer had a
telephonic discussion during which Ms. Ciraolo indicated that Mr.
Gazi wanted to post a bond in lieu of respondent’s filing a
notice of Federal tax lien.
On August 30, 2005, Mr. Gazi and Ms. Gazi’s estate filed
with the Court a motion for reconsideration of the July 28, 2005
Opinion.
On August 30, 2005, Ms. Ciraolo informed the revenue
officer that Mr. Gazi had not filed a bond and that the motion
for reconsideration of the July 28, 2005 Opinion had been filed
with the Court. Thereafter, in September 2005, a notice of
Federal tax lien was filed with respect to each of the Gazis’
taxable years 1983 through 1989.
5For purposes of opinion only, the Gazis’ Tax Court case was
consolidated with another case. All Cmty. Walk In Clinic v.
Commissioner, T.C. Memo. 2005-190.
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