John P. Crowley and Elizabeth R. Cockrell - Page 9

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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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