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LONG v. COMMISSIONER

Docket No. 9088-76.

71 T.C. 724 (1979)

MARSHALL LONG AND BETTY C. LONG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 5, 1979.

Attorney(s) appearing for the Case

Daniel C. Weary and Dennis P. Wilbert, for the petitioners.

Larry K. Akins, for the respondent.

SUPPLEMENTAL OPINION

TIETJENS, Judge:

Petitioners have filed a motion for reconsideration of findings and opinion under Rule 161, Tax Court Rules of Practice and Procedure, requesting us to reconsider our opinion in Long v. Commissioner, 71 T.C. 1 (1978). The facts in Long are detailed, so a brief recitation of them may be helpful.

Petitioner Marshall Long, as the beneficiary of an estate, claimed...

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