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EDWARD v. COMMISSIONER

Docket No. 4063-02L.

86 T.C.M. 585 (2003)

T.C. Memo. 2003-312

Edward H. and Anne G. Harrell v. Commissioner.

United States Tax Court.

Filed November 12, 2003.

Attorney(s) appearing for the Case

Guy C. Crowgey, for the petitioners.

Mary Ann Waters, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

NIMS, Judge:

Respondent moves the Court for reconsideration of its Memorandum Opinion at T.C. Memo. 2003-271. See Rule 161. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.

In Harrell v. Commissioner [Dec. 55,298(M)],

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