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permissible subject of a Rule 155 computational proceeding. See
Rule 155(c). We agree with respondent.
Rule 155 is this Court’s procedural mechanism to enable the
entry of a decision in specific dollar amounts attributable to
the Court’s and parties’ resolution/disposition of the issues in
a case. Cloes v. Commissioner, 79 T.C. 933, 935 (1982).
Paragraph (c) of Rule 155 provides:
(c) Limit on Argument: Any argument under this
Rule will be confined strictly to consideration of the
correct computation of the deficiency, liability, or
overpayment resulting from the findings and conclusions
made by the Court, and no argument will be heard upon
or consideration given to the issues or matters
disposed of by the Court’s findings and conclusions or
to any new issues. This Rule is not to be regarded as
affording an opportunity for retrial or
reconsideration.
Issues that have been litigated at the trial of a case may
not be relitigated in connection with the entry of decision under
Rule 155. Cloes v. Commissioner, supra. Our prior opinion
expressly concludes that petitioners, on their return, claimed
$112,470 in renovations as part of the cost of their new
residence. Mitchell v. Commissioner, T.C. Memo. 1997-493. We
find petitioners’ argument surprising considering that they
vigorously, and at some length, argued that the renovations in
question were completed prior to the 2-year replacement
deadline.2
2 We note that petitioners did not file a motion for
(continued...)
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