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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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