T.C. Memo. 2003-312
UNITED STATES TAX COURT
EDWARD H. AND ANNE G. HARRELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 4063-02L. Filed November 12, 2003.
R filed a motion for reconsideration of our
opinion in Harrell v. Commissioner, T.C. Memo. 2003-
271, arguing that our disposition of this case
constitutes both substantial error and unusual
circumstances. R claims that the language in our
opinion was ambiguous as to whether respondent’s
decision to issue the notice of determination was an
abuse of discretion.
Held: We reaffirm our holding in Harrell v.
Commissioner, supra, that R’s decision to issue the
notice of determination was an abuse of discretion.
R’s motion for reconsideration is denied.
*This opinion supplements our opinion in Harrell v.
Commissioner, T.C. Memo. 2003-271.
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