110 T.C. No. 32 UNITED STATES TAX COURT ESTATE OF ROBERT W. QUICK, DECEASED, ESTHER P. QUICK, PERSONAL REPRESENTATIVE, AND ESTHER P. QUICK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 8588-97. Filed June 29, 1998. Ps filed a Motion for Reconsideration of our Opinion reported as Estate of Quick v. Commissioner, 110 T.C. 172 (1998). Among other things, Ps argue that our failure therein to order refunds for overpayments of tax for Ps' 1989 and 1990 tax years stemming from the "proper" computational adjustments which R should have made for those years, as well as refunds for overpayments for their 1987 and 1988 tax years attributable to NOL carrybacks from 1989 and 1990, was erroneous. Held: Ps' Motion for Reconsideration is denied; this Court has jurisdiction to determine overpayments of tax, if any, attributable to affected items as part of a decision of this case (sec. 6512(b)(1), I.R.C.; Woody v. Commissioner, 95 T.C. 193, 206, 209 (1990), followed); this Court lacks * This opinion supplements our previously filed Opinion in Estate of Quick v. Commissioner, 110 T.C. 172 (1998).Page: 1 2 3 4 5 6 7 8 9 Next
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