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granting of a motion for reconsideration rests with the
discretion of the Court, and we usually do not exercise our
discretion absent a showing of unusual circumstances or
substantial error. CWT Farms, Inc. v. Commissioner, 79 T.C.
1054, 1057 (1982), affd. 755 F.2d 790 (11th Cir. 1985).
Reconsideration is not the appropriate forum for rehashing
previously rejected legal arguments or tendering new legal
theories to reach the end result desired by the moving party.
Stoody v. Commissioner, 67 T.C. 643, 644 (1977); Estate of
Scanlan v. Commissioner, supra.
Petitioners' argument that the section 469 issue cannot be
an affected item for purposes of the applicability of TEFRA's
audit and litigation provisions was raised previously and
received thorough consideration by this Court. Estate of Quick
v. Commissioner, supra. Petitioners' Motion does not evince any
unusual circumstances or substantial error with respect to this
issue. We therefore decline to reconsider this issue or to
elaborate on it any further. See Stoody v. Commissioner, supra
at 644.
Petitioners next contend that, even if the section 469 issue
is an affected item requiring partner level factual
determinations, the Court erred in failing to order refunds for
overpayments of taxes paid for 1989 and 1990, as well as refunds
for overpayments for 1987 and 1988 resulting from net operating
loss carrybacks from 1989 and 1990. In petitioners' view,
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