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CHRONICLE PUBLISHING CO. v. COMMISSIONER

Docket No. 18740-90.

63 T.C.M. 1899 (1992)

T.C. Memo. 1992-45

The Chronicle Publishing Company and Subsidiaries v. Commissioner.

United States Tax Court.

Filed January 27, 1992.

Attorney(s) appearing for the Case

Robert C. Livsey, One Market Plaza, San Francisco, Calif., for the petitioner. Ann M. Murphy, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

This case is before us on petitioner's motion for reconsideration and revision of our opinion, 97 T.C. 445 (1991). In that opinion, we directed our attention, in accordance with the arguments of the parties, to the issue of whether petitioner's clipping library fell within the category of "a letter or memorandum, or similar property" specified in section 1221(3)1

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