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motion, Stoody v. Commissioner, 67 T.C. 643, 644 (1977), or to
hear arguments that could have been made before the filing of an
opinion, Estate of Trenchard v. Commissioner, T.C. Memo. 1995-
232. Moreover, as we observed in Koufman v. Commissioner, 69
T.C. 473, 476-477 (1977):
This Court has an extraordinarily heavy volume of
cases, and in many of them, the Court decides an issue
against one of the parties because of his failure to
carry his burden of proof or to perform some other act.
If the Court granted a second chance to every party who
lost because of his failure to act in some manner, the
Court clearly could not keep abreast of its work. In
effect, we would be telling the parties that if they
were not satisfied with the first decision, try again.
However, on previous occasions, we have denied a peti-
tioner's motion to vacate the decision and reconsider
the opinion where the only basis for these motions was
the petitioner's unexcused failure to raise certain
issues earlier. * * *
Similarly, in denying the taxpayers' motion for reconsideration
in Long v. Commissioner, 71 T.C. 724, 727 (1979), remanded on
another issue 660 F.2d 416 (10th Cir. 1981), we observed:
A party is entitled to have his day in court; both
parties are entitled to this, but neither party is
entitled to have more than one fair, reasonable oppor-
tunity to establish his claim or defense. To allow
more would be to protract litigation to the extent
which would preclude the administration of justice.
[Selwyn Operating Corp. v. Commissioner, 11 B.T.A. 593,
595 (1928).]
The parties cannot try their cases with hind-
sight.
By way of background, we shall restate certain of the
findings and conclusions in our Opinion that are pertinent to our
consideration of the respective motions for reconsideration of
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