Estate of Robert W. Quick, Deceased, Esther P. Quick, Personal Representative, and Esther P. Quick - Page 1

                                   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).                       

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