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Discussion
The granting of a motion for reconsideration rests within
the discretion of the Court. Estate of Quirk v. Commissioner,
928 F.2d 751, 759 (6th Cir. 1991), affg. in part and remanding in
part T.C. Memo. 1988-286; Klarkowski v. Commissioner, 385 F.2d
398, 401 (7th Cir. 1967), affg. T.C. Memo. 1965-328. A motion
for reconsideration will be denied unless unusual circumstances
or substantial error is shown. Estate of Quirk v. Commissioner,
supra at 759; Alexander v. Commissioner, 95 T.C. 467, 469 (1990),
affd. without published opinion sub nom. Stell v. Commissioner,
999 F.2d 544 (9th Cir. 1993); Vaughn v. Commissioner, 87 T.C.
164, 167 (1986).
Petitioners’ motion for reconsideration fails to address the
Court’s holdings in Richards I that the Court does not have
jurisdiction over the cases at docket Nos. 10764-00 and 10767-
12(...continued)
Order, the Court directed respondent to file a response to
petitioners’ motion for reconsideration and a response to peti-
tioners’ motion to reopen the record only if respondent believed
that it was necessary to file each such response. Obviously,
respondent did not believe that it was necessary to file any
responses to those motions.
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