Opinion
2265-19
10-04-2023
CLARK RAYMOND & COMPANY PLLC, D. EDSON CLARK, CPA, PLLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson Judge
We issued our opinion in this case as T.C. Memo. 2022-105 (Doc. 45), on October 13, 2022, and we entered our order and decision on July 26, 2023 (Doc. 64). Now before us is petitioner's motion for reconsideration and to vacate or revise decision (Doc. 65), filed on August 17, 2023. The Commissioner filed an objection (Doc. 74), and petitioner filed a reply (Doc. 75). It is
ORDERED that petitioner's motion is denied, for the reasons stated in the Commissioner's objection.