Supplemental Memorandum Opinion
CLAPP, Judge:
This case is before us on petitioner's Motion to Vacate or Revise Decision filed February 2, 1990. Respondent filed a Notice of Objection on March 9, 1990. All section references are to the Internal Revenue Code for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
On December 28, 1989, we filed our opinion in this case, which is reported at [Dec. 46,238...
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