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REINECKE v. COMMISSIONER

Docket No. 33433.

12 T.C.M. 1370 (1953)

Mignon Reinecke v. Commissioner.

United States Tax Court.

Entered December 4, 1953.

Attorney(s) appearing for the Case

Henry C. Lowenhaupt, Esq., 408 Olive Street, St. Louis, Mo., for the petitioner. Ray H. Garrison, Esq., for the respondent

Supplemental Opinion

OPPER, Judge:

Aside from petitioner's failure in her motion for a further hearing to show that evidence now claimed to be newly discovered could not have been found sooner by the exercise of reasonable diligence,1 one of the other requisites of a successful application for a new or further trial because of newly discovered evidence is that the new evidence should be adequate

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