- 6 -
Trenchard v. Commissioner, T.C. Memo. 1995-232; see 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 usually do not
exercise our discretion to grant such a motion absent a showing
of unusual circumstances or substantial error. Vaughn v.
Commissioner, 87 T.C. 164, 166-167 (1986); CWT Farms, Inc. v.
Commissioner, 79 T.C. 1054, 1057 (1982), affd. 755 F.2d 790 (11th
Cir. 1985); Haft Trust v. Commissioner, 62 T.C. 145, 147 (1974),
affd. on this issue, vacated and remanded 510 F.2d 43, 45 n.1
(1st Cir. 1975).
Reconsideration is not the appropriate forum for rehashing
previously rejected arguments or tendering new legal theories to
reach the end desired by the moving party. Estate of Trenchard
v. Commissioner, supra. The Court tries all issues raised in a
case in one proceeding to promote orderly litigation and to
further judicial economy by discouraging piecemeal and protracted
litigation. Vaughn v. Commissioner, supra at 166-167; CWT Farms,
Inc. v. Commissioner, supra at 1057; Stoody v. Commissioner, 67
T.C. 643 (1977); Haft Trust v. Commissioner, supra at 147.
However, the RRA 1998 was enacted on July 22, 1998, after
the previous opinions in this case. Section 3201(g)(1) of the
RRA 1998, 112 Stat. 740, provides that section 6015 applies to
any tax liability arising after July 22, 1998, and any tax
liability arising on or before July 22, 1998, and remaining
unpaid as of that date. Section 3201(g)(2) of the RRA 1998
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