Opinion
18104-17L
11-19-2021
MICHAEL D. BROWN, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER
Kathleen Kerrigan Judge
On September 23, 2021, the Court released T.C. Memo 2021-112, which held that this Court does not have jurisdiction to order a refund of petitioner's TIRPRA payment. On October 21, 2021, petitioner filed a motion for reconsideration of finding or opinion pursuant to Rule 161. Respondent filed an objection to petitioner's motion on November 15, 2021.
All Rule reference are to the Tax Court Rules of Practice and Procedure.
Reconsideration under Rule 161 is for the purpose of correcting substantial errors of fact or law. See Estate of Quick v. Commissioner, 110 T.C. 440, 441 (1998). After revieing petitioner's motion and respondent's response, it is
ORDERED that petitioner's motion for reconsideration of finding or opinion pursuant to Rule 161 is denied.