SUPPLEMENTAL MEMORANDUM OPINION
HAINES, Judge:
On April 20, 2006, petitioner filed a Motion for Reconsideration of Findings or Opinion under Rule 161, and a Motion to Vacate or Revise a Decision under Rule 162 (collectively, the motions).
The Court incorporates herein its Findings of Fact in Parker v. Commissioner [Dec. 56,449(M)],
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