John G. Goettee, Jr. and Marian Goettee - Page 8

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         periods is a departure from petitioners’ briefs; (3) the record              
         supports respondent’s prioritization decisions; (4) the alleged              
         delay in assessing the liabilities does not warrant additional               
         periods of abatement; and (5) the Court’s conclusion that                    
         interest should not be abated for April 25, 1995, is correct.                
         Respondent concludes that petitioners’ amended motion for                    
         reconsideration should be denied.                                            
              We agree with respondent’s conclusion.                                  
              Reconsideration under Rule 161 permits the Court to correct             
         manifest errors of fact or law and allows a party to introduce               
         newly discovered evidence that could not have been introduced in             
         a prior proceeding even if the moving party had exercised due                
         diligence.  See Estate of Quick v. Commissioner, 110 T.C. 440,               
         441 (1998); see also Traum v. Commissioner, 237 F.2d 277, 281                
         (7th Cir. 1956), affg. T.C. Memo. 1955-127.  The granting of a               
         motion for reconsideration rests within the discretion of the                
         Court, and we generally deny such a motion unless unusual                    
         circumstances or substantial error is shown.  See 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); Estate of Halas v. Commissioner, 94 T.C. 570, 574 (1990);             
         Vaughn v. Commissioner, 87 T.C. 164, 166-167 (1986).                         
         Reconsideration is not the appropriate forum for rehashing                   
         previously rejected arguments or offering new legal theories to              

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