- 34 - ity to act on its behalf in each such case. We remind petitioners that If the Court granted a second chance to every party who lost because of his failure to act in some manner, the Court clearly could not keep abreast of its work. In effect, we would be telling the parties that if they were not satisfied with the first decision, try again. * * * Koufman v. Commissioner, 69 T.C. 473, 476 (1977).14 We find that petitioners have not shown any unusual circum- stances or substantial error that warrants the Court’s relieving them of the consequences of their conduct in these cases by granting petitioners’ motion for reconsideration. We have considered all of the arguments and contentions set forth in petitioners’ motion for reconsideration that are not discussed herein, and we find them to be without merit and/or irrelevant.15 14See also Long v. Commissioner, 71 T.C. 724, 727 (1979), remanded on another issue 660 F.2d 416 (10th Cir. 1981), in which we quoted the following passage from Selwyn Operating Corp. v. Commissioner, 11 B.T.A. 593, 595 (1928): A party is entitled to have his day in court; both parties are entitled to this, but neither party is entitled to have more than one fair, reasonable oppor- tunity to establish his claim or defense. To allow more would be to protract litigation to the extent which would preclude the administration of justice. 15With respect to petitioners’ reliance in petitioners’ motion for reconsideration on Alvarez v. Simmons Mkt. Research Bureau, Inc., 839 F.2d 930 (2d Cir. 1988); Harper v. Commis- sioner, 99 T.C. 533 (1992); Marcus v. Commissioner, 70 T.C. 562 (1978), affd. without published opinion 621 F.2d 439 (5th Cir. (continued...)Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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