United States v. Craddock

BRORBY, Circuit Judge.

Mr. James Berry Craddock petitions this court for rehearing on the issue of his substantial understatement of tax penalty addressed in our opinion, In re Craddock, 143 F.3d 595, 1998 WL 213685 (10th Cir. May 1, 1998). We grant Mr. Craddock’s petition, in part, as to our standard of deference applicable to a treasury regulation, and the application of this standard to Treas. Reg. § 1.6661-2(e) — (d). We deny his petition as to all other issues and deny his suggestion for rehearing en banc. The original opinion is withdrawn. This opinion is ordered substituted for the…