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F. Additions to Tax
In their motion, petitioners elaborate on the arguments
which they made on brief regarding the additions to tax assessed
against INC and Holdings pursuant to sections 6653 and 6661.
Generally, we do not grant reconsideration to resolve arguments
which could have been raised during the prior proceedings. CWT
Farms, Inc. v. Commissioner, 79 T.C. at 1057. Consequently, we
do not reconsider our holdings in our prior opinion sustaining
respondent's determination of additions to tax for INC and
Holdings pursuant to sections 6653 and 6661.
We have considered all of the remaining arguments made by
petitioners in their motion and find such arguments to be without
merit.15 To reflect the foregoing,
Appropriate orders
will be issued.
15 Although not raised by the parties, paragraphs numbered 3
and 4 on page 10, paragraph numbered 3.b. on page 221, and
paragraph numbered 3.c. on page 222 in our prior opinion were
unnecessary because the matters covered by those paragraphs were
covered by the parties in their stipulation and did not require a
decision by the Court. Consequently, in our order to be issued
pursuant to this opinion, we will delete those paragraphs from
our prior opinion.
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