McKnight v. Commissioner
United States Tax Court
Ps filed a motion to vacate and a motion to reconsider our opinion in this case, McKnight v. Commissioner,T.C. Memo. 1991-514, asserting that sec. 301.6231(a)(1)-1T(a)(3), Temporary Proced. & Admin. Regs., 52 Fed.
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Ps filed a motion to vacate and a motion to reconsider our opinion in this case, McKnight v. Commissioner,T.C. Memo. 1991-514, asserting that sec. 301.6231(a)(1)-1T(a)(3), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6789 (Mar. 5, 1987), as the Commissioner and this Court have thus far interpreted it, renders the regulation invalid as it conflicts with the intent of Congress in enacting sec. 6231(a)(1), I.R.C.Held, Ps' motions are denied since sec. 301.6231(a)(1)-1T(a)(3), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6789 (Mar. 5, 1987), implements the congressional mandate of sec.…
1Opinion of the Court
SUPPLEMENTAL OPINION
Parr, Judge:
On August 6, 1991, petitioners filed a motion to dismiss for lack of jurisdiction. This motion was objected to by respondent on September 20, 1991. Thereon, petitioners filed a motion for leave to file a response to respondent’s notice of objection which was denied by this Court on October 4, 1991.
On October 9, 1991, we filed our opinion in this case, McKnight v. Commissioner, T.C. Memo. 1991-514 (McKnight I), denying petitioners’ motion to dismiss for lack of jurisdiction. Petitioners filed a motion for reconsideration of findings or opinion under Rule 161,…
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