- 33 -
such relevant information. Instead, they failed to prosecute
their respective cases, ignored all Orders of the Court, and
submitted to the Court documents containing statements, conten-
tions, and arguments that were frivolous and/or groundless. In
addition, the named petitioner in each of the cases at docket
Nos. 10764-00 and 10767-00 failed to establish who has the
authority 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).16
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
16See 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.
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