Intermountain Insurance Service of Vail, Ltd. Liability Co. v. Commissioner
United States Tax Court
R filed a motion to vacate the Court's prior decision and a motion to reconsider the Court's prior opinion. R's motions are premised on the retroactive application of temporary regulations issued after the Court issued its opinion and entered its decision. Held: R's motions to reconsider and to vacate will be denied.
1Opinion of the Court
SUPPLEMENTAL OPINION
Wherry, Judge:
We issued an opinion and entered our decision in this case on September 1, 2009. Relying on Bakersfield Energy Partners, LP v. Commissioner, 128 T.C. 207 (2007), affd. 568 F.3d 767 (9th Cir. 2009), we decided that the adjustments made in respondent’s final partnership administrative adjustment (fpaa) on which this case is based are barred by the general 3-year period of limitations in section 6501(a).1 See Intermountain Ins. Serv. of Vail, LLC v. Commissioner, T.C. Memo. 2009-195. Respondent subsequently issued two temporary regulations, sections…
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