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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