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a taxpayer is not required to offer any evidence of net worth
when the Commissioner objects to the taxpayer's affidavit and net
worth schedule. Petitioners also suggest that an evidentiary
hearing is required.
Reconsideration under Rule 161 permits us to correct
manifest errors of fact or law, or to allow newly discovered
evidence to be introduced that could not have been introduced
before the filing of an opinion, even if the moving party had
exercised due diligence. See Rothwell Cotton Co. v. Rosenthal &
Co., 827 F.2d 246, 251, amended per order 835 F.2d 710 (7th Cir.
1987); see also Traum v. Commissioner, 237 F.2d 277, 281 (7th
Cir. 1956), affg. T.C. Memo. 1955-127. The granting of a motion
for reconsideration rests within the discretion of the Court, and
we shall not grant a motion for reconsideration unless the party
seeking reconsideration shows unusual circumstances or
substantial error. See Alexander v. Commissioner, 95 T.C. 467,
469 (1990), affd. sub nom. without published opinion Stell v.
Commissioner, 999 F.2d 544 (9th Cir. 1993); Estate of Halas v.
Commissioner, 94 T.C. 570, 573 (1990); Vaughn v. Commissioner, 87
T.C. 164, 166-167 (1986); Estate of Bailly v. Commissioner, 81
T.C. 949, 951 (1983); Haft Trust v. Commissioner, 62 T.C. 145,
147 (1974), affd. on this issue 510 F.2d 43, 45 n.1 (1st Cir.
1975). Reconsideration is not the appropriate forum for
rehashing previously rejected legal arguments or tendering new
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