United States Tax Court April 6, 1995, Docket Nos. 19305-91, 19306-91 (Norfolk Southern Corp. v. Commissioner)

SUPPLEMENTAL OPINION

Parr, Judge:

The Court’s opinion in these cases, 104 T.C. 13 (1995), was issued on January 11, 1995 (prior opinion). Thereafter, on February 13, 1995, pursuant to Rule 161,1 respondent filed a motion for reconsideration of opinion. The Court directed petitioners to file a response to respondent’s motion.