Templeton v. Commissioner
United States Tax Court
The petitioners filed motions to vacate our decision in Frank G. Templeton, 66 T.C. 509 (1976), and to reconsider our opinion in that case, asserting that two paragraphs of the stipulation were inaccurate and that their correction would warrant a reversal of our holding. Held: The motion to reconsider is granted, and the facts in the case are revised accordingly; however, the changed facts do not lead to a different holding. The motion to vacate is therefore denied.
1Opinion of the Court
SUPPLEMENTAL OPINION
Simpson, Judge:
After entry of the decision in Frank G. Templeton, 66 T.C. 509 (1976), the petitioners filed a motion to vacate and revise decision and a motion for reconsideration of opinion. In such motions, they claimed that two paragraphs of the stipulation of facts had been misunderstood and that, as a consequence, the result in that case was erroneous. The Commissioner filed his objections to both motions and requested that the parties be allowed to file a supplemental stipulation of facts. This Court authorized the filing of a supplemental stipulation of facts and…
2Cases cited6 opinions
- Lucile McAulay Filippini, as of the Last Will and Testament of Carra McAulay Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 1963
- Kimbell-Diamond Milling Co. v. CommissionerUnited States Tax Court · 1948
- Gaynor News Co. v. CommissionerUnited States Tax Court · 1954
- John Richard Corp. v. CommissionerUnited States Tax Court · 1966
- Henderson Overland Co. v. CommissionerUnited States Board of Tax Appeals · 1926
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3Cited by4 opinions
- Taft Broadcasting Company v. United StatesCourt of Appeals for the Sixth Circuit · 1991
- Kahl v. CommissionerUnited States Tax Court · 1986
- Taft Broadcasting Co. v. United StatesDistrict Court, S.D. Ohio · 1988
- Templeton v. CommissionerUnited States Tax Court · 1976