OPINION ON MOTION TO RECONSIDER OR MODIFY MANDATE
PER CURIAM.
On motion to reconsider or modify the remand orders in these cases we have been asked to reconsider our mandate directing the United States Tax Court to assess attorney's fees and double costs for the bringing of a frivolous appeal. The government suggests that there is some doubt that the Tax Court has jurisdiction to award attorney's fees and costs in these cases. Without deciding the issue...
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