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previously rejected arguments or tendering new legal theories to
reach the end desired by the moving party. See CWT Farms, Inc.
v. Commissioner, 79 T.C. 1054, 1057 (1982), affd. 755 F.2d 790
(11th Cir. 1985); Stoody v. Commissioner, 67 T.C. 643 (1977);
Estate of Trenchard v. Commissioner, T.C. Memo. 1995-232.
Petitioner's motion and related filings do not establish any
unusual circumstance or substantial error with respect to
Dynadeck Rotary Sys. v. Commissioner, supra. Thus, petitioner is
not within the general rules for reconsideration of a Memorandum
Opinion. Petitioner has also not persuaded us that the
Partnership’s case requires us to depart from these general
rules. In his trial brief, petitioner argued that the
Corporation received the $400,000 as the Partnership’s agent.
For the reasons stated in Dynadeck Rotary Sys. v. Commissioner,
supra, we disagreed with that argument. Petitioner now asks us
to reconsider and accept that argument. We refuse to do so.
Petitioner has not presented any persuasive reason why we should
reconsider or change Dynadeck Rotary Sys. v. Commissioner,
supra.1 To the extent that petitioner had wanted either to
1 Petitioner’s motion relies, in part, on a document that
petitioner attached to his posttrial brief. The document is
entitled “Declaration of Martin N. Lettunich” and contains Mr.
Lettunich’s assertions as to his understanding of the events
surrounding the $400,000 debt. We did not and do not consider
that document (or the assertions stated therein) as evidence.
See Rule 143(b); see also Beecroft v. Commissioner, T.C. Memo.
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