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SEARS, ROEBUCK & CO. v. COMMISSIONER

Docket No. 2165-89.

96 T.C. 671 (1991)

SEARS, ROEBUCK AND CO. AND AFFILIATED CORPORATIONS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 24, 1991.

Attorney(s) appearing for the Case

Frederic W. Hickman, Patrick A. Heffernan, Michael M. Conway, Michael A. Clark, Richard Bromley, Paul S. Caselton, Bradford L. Ferguson, Burton H. Litwin, and Michael R. Schlessinger, for the petitioner.

Beth L. Williams, Teri A. Frank, Charles W. Maurer, Jr., and Christopher J. Faiferlick, for the respondent.

SUPPLEMENTAL OPINION

COHEN, Judge:

On January 24, 1991, our opinion in the above case was filed at 96 T.C. 61. That opinion addressed two issues, the "insurance premiums issue" and the "mortgage guaranty insurance issue." The insurance premiums issue was decided in favor of petitioner, and the mortgage guaranty insurance issue was decided in favor of respondent.

On February 21, 1991, respondent filed a motion...

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