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intentions. Mecom v. Commissioner, 101 T.C. 374, 385
(1993), affd. without published opinion 40 F.3d 385 (5th
Cir. 1994); Kornish v. Commissioner, 90 T.C. 684, 693
(1988). In this case, petitioners intentionally signed the
subject consent form and thereby manifested their assent to
the terms contained therein. According to Mr. Brody's
affidavit, he harbored the unstated view that respondent's
agent had made a mistake in preparing the consent by
limiting it to adjustments from Thunderbird. Mr. Brody's
affidavit does not suggest that petitioners misunderstood
what was intended by the restrictive language in the
consent or that they intended a different restriction.
Petitioners merely harbored the secret belief that the
consent would not have the legal effect of extending the
period of limitations with respect to their 1978 return.
Thus, petitioners made a unilateral mistake concerning the
legal effect of the consent. This is not the type of
mistake for which relief is warranted. See Estate of
Caporella v. Commissioner, 86 T.C. 285, 298 (1986), affd.
817 F.2d 706 (11th Cir. 1987); 13 Williston on Contracts,
sec. 1587 (3d ed. 1970).
Petitioners claim that the "new and additional
information" submitted with their cross-motion for summary
judgment shows that the Court misconstrued respondent's
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