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Crowley may deduct 20 percent of the losses attributable to the
commodities straddle transactions for the years in issue, subject
to petitioner's right to contest her liability for the taxes
arising out of the settlement pursuant to section 6013(e). The
settlement agreement contains standard settlement terms offered
by respondent to all taxpayers involved in the Arbitrage
Management tax shelter litigation project.
Discussion
The decision to grant a motion for reconsideration rests
within the discretion of the Court and such a motion will not be
granted unless unusual circumstances or substantial error is
shown. Vaughn v. Commissioner, 87 T.C. 164, 166-167 (1986).
Moreover, it is our policy to try all of the issues raised in a
case in one proceeding in order to avoid piecemeal and protracted
litigation. Alexander v. Commissioner, 95 T.C. 467, 469 (1990).
Petitioner contends in her motion for reconsideration that
we incorrectly held in our prior Opinion that the understatements
in issue were not attributable to "grossly erroneous items".
However, before deciding whether petitioner would be entitled to
relief from liability as an innocent spouse if we were to accept
that contention, we shall consider whether petitioner fails to
satisfy any of the other requirements for innocent spouse relief
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