- 2 -
by Ronald Gordon (Mr. Gordon) and the motion filed by Beverly
Gordon (Ms. Gordon) for reconsideration1 of certain findings in
our Opinion in Gordon v. Commissioner, T.C. Memo. 1997-193
(Opinion).2 We incorporate our Opinion herein by this reference.
The granting of a motion for reconsideration rests within
the discretion of the Court. Estate of Quirk v. Commissioner,
928 F.2d 751, 759 (6th Cir. 1991), affg. in part and remanding in
part T.C. Memo. 1988-286; Klarkowski v. Commissioner, 385 F.2d
398, 401 (7th Cir. 1967), affg. T.C. Memo. 1965-328. A motion
for reconsideration will be denied unless unusual circumstances
or substantial error is shown. Estate of Quirk v. Commissioner,
supra at 759. It is the policy of this Court to try all issues
raised in a case in one proceeding to avoid piecemeal and pro-
tracted litigation. Haft Trust v. Commissioner, 62 T.C. 145, 147
(1974), affd. on this issue 510 F.2d 43, 45 n.1 (1st Cir. 1975).
A motion for reconsideration generally will not be granted to
resolve issues that are raised for the first time in such a
1 Ms. Gordon's motion for reconsideration was accompanied by a
memorandum in support thereof. We shall refer collectively to
that motion and that memorandum as either Ms. Gordon's motion for
reconsideration or Ms. Gordon's motion. We shall refer to Mr.
Gordon's motion for reconsideration as either Mr. Gordon's motion
for reconsideration or Mr. Gordon's motion.
2 Respondent filed a separate notice of objection to each of
those motions and a memorandum in support of the notice of
objection to Ms. Gordon's motion. The Court permitted Ms. Gordon
to file a response to Mr. Gordon's motion and permitted Mr.
Gordon to file a response to Ms. Gordon's motion. However,
neither Ms. Gordon nor Mr. Gordon filed such a response.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011