ON PETITION FOR PANEL REHEARING

IT IS ORDERED that the petition for panel rehearing is DENIED. As Appellees point out in the petition for panel rehearing, the opinion mistakenly referenced Ap-pellees’ tax returns in Part III and not the Odyssey partnership return. Part III of the opinion should have stated that Odyssey’s amended Form 1065 did not substan *938 tially comply with the regulatory requirements of an AAR. See Samueli v. C.I.R., 132 T.C. 336, 346 (2009) (holding that an amended return did not substantially comply with the requirements of an AAR because, in part, it “did not include all information required to be provided on a Form 8082”). The rest of the opinion’s analysis, including its reliance on Rigas v. United States, 486 Fed.Appx. 491 (5th Cir. 2012), remains unchanged.