- 4 -
an opinion. Reconsideration is not the appropriate forum for
rehashing previously rejected arguments or tendering new legal
theories to reach the end desired by the moving party. The Court
tries all issues raised in a case in one proceeding to promote
orderly litigation and to further judicial economy by
discouraging piecemeal and protracted litigation. CWT Farms,
Inc. v. Commissioner, supra at 1057; Stoody v. Commissioner,
67 T.C. 643 (1977); see also Estate of Trenchard v.
Commissioner, supra.
Petitioner's motion and memorandum do not list (or otherwise
show) any unusual circumstance or substantial error with respect
to our memorandum opinion. Thus, petitioner is not within the
general rules for reconsideration of an opinion. Petitioner has
also not persuaded us that this case requires us to depart from
these general rules. In its trial brief, petitioner primarily
argued that the Court should accept the values set forth by its
expert, Mr. Chaffe. Petitioner also argued that the Mandelbaum
factors confirmed that the 35-percent marketability discount used
by Mr. Chaffe in ascertaining his value was not excessive.
For the reasons stated in Estate of Trenchard v.
Commissioner, T.C. Memo. 1995-121, we disagreed with all of
petitioner's arguments. Petitioner now asks us to reconsider our
memorandum opinion in Estate of Scanlan v. Commissioner, T.C.
Memo. 1996-331 and rewrite it to conform to Mr. Chaffe's
conclusion on value. We decline to do so. Petitioner has not
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011