Opinion
14367-21 14370-21
10-18-2023
JOHN P. JANICKI & KATHERINE S. JANICKI, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch, Judge.
On October 6, 2023, the Court issued an Order denying petitioners' Motion for Partial Summary Judgment. That Order contained a non-substantive editing error. To correct that error, it is
ORDERED that the Court's Order served October 6, 2023, is amended as follows: the second sentence of the fourth paragraph of the first page of the Order is deemed stricken and the following sentence is deemed to be substituted in its place: "Because section 41(g) unambiguously requires that credits subject to its limitation also remain subject to the section 38(c) limitation, we must deny petitioners' Motion for Partial Summary Judgment."