- 6 - Bailly v. Commissioner, 81 T.C. 949, 951 (1983). Reconsideration is not the appropriate forum for rehashing previously rejected legal arguments or tendering new legal theories to reach the end result desired by the moving party. See Estate of Quick v. Commissioner, supra at 441-442; Stoody v. Commissioner, 67 T.C. 643, 644 (1977). Respondent’s main contention in support of his motion for reconsideration is that this Court was ambiguous in Harrell v. Commissioner, T.C. Memo. 2003-271, as to whether the issuance of the Notice of Determination, without awaiting the Supreme Court’s opinion in Young v. United States, 535 U.S. 43 (2002), was an abuse of discretion. For the sake of clarity, we deem it necessary to discuss our rationale in greater detail than we did previously. As of January 22, 2002, the date of the Notice of Determination upon which this case is based, the Supreme Court had not as yet decided Young, which had been argued on January 9, 2002, but was not decided until March 4, 2002. In this case, the Supreme Court held that the 3-year lookback period in bankruptcy cases is automatically tolled during the pendency of an earlier proceeding under the Bankruptcy Code. In Harrell v. Commissioner, supra, we stated that we were “reluctant to label respondent’s issuance of the Notice of Determination an abuse of discretion based upon a somewhatPage: Previous 1 2 3 4 5 6 7 8 Next
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