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SUPPLEMENTAL MEMORANDUM OPINION
WELLS, Judge: These cases1 are before us on petitioner
Elizabeth R. Cockrell's2 motion pursuant to Rule 1613 for
reconsideration of Crowley v. Commissioner, T.C. Memo. 1993-503
(prior Opinion). In our prior Opinion, we held, inter alia, that
petitioner was not entitled to relief under section 6013(e) as an
innocent spouse from the understatements of tax for her taxable
years 1980 and 1981 attributable to deductions claimed for losses
incurred by Mr. Crowley in connection with certain commodities
straddle transactions. That holding was based on petitioner's
failure to prove that such understatements of tax were
attributable to "grossly erroneously items" pursuant to section
6013(e)(2)(B).4
1
These cases (for convenience, hereinafter referred to as the
instant case) have been consolidated for trial, briefing, and
opinion.
2
As petitioner John P. Crowley has settled all issues in the
instant case with respect to himself, hereinafter we will refer
to Elizabeth R. Cockrell as "petitioner" and John P. Crowley as
Mr. Crowley.
3
Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years in issue.
4
Because the requirements for relief as an innocent spouse
under sec. 6013(e) are conjunctive, Bokum v. Commissioner, 94
T.C. 126, 138 (1990), affd. 992 F.2d 1132 (11th Cir. 1993), our
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