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SEYKOTA v. COMMISSIONER

Docket Nos. 14936-82, 47868-86, 6720-87, 31972-87.

62 T.C.M. 1116 (1991)

T.C. Memo. 1991-541

Edward A. Seykota, et al. v. Commissioner.

United States Tax Court.

Filed October 29, 1991.

Attorney(s) appearing for the Case

Stuart E. Seigel,2 F. Whitten Peters, Matthew D. Lerner, Marie T. Reilly, and William M. Wiltshire, 839 Seventeenth St., N.W., Washington, D.C., for the petitioners. Theodore L. Craft, for the petitioners in Docket No. 6720-87. William C. Sabin, Jr., Marsha Keyes, Kathleen E. Whatley, and C. Ted Sanderson, for the respondent.

Supplemental Memorandum Opinion

DAWSON, Judge:

On May 28, 1991, the Court filed its Memorandum Findings of Fact and Opinion in this case, adopting the opinion of Special Trial Judge Peter J. Panuthos. See Seykota v. Commissioner [Dec. 47,368(M)], T.C. Memo. 1991-234.

Respondent has filed a motion for reconsideration, accompanied by a memorandum in support thereof. Petitioners filed their objections to...

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