- 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.
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