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entertain petitioners’ more detailed request. As we stated,
supra, reconsideration is not the appropriate forum for offering
new legal theories or rehashing previously rejected arguments to
reach the desired result.
3. Dec. 2, 1993, through Oct. 26, 1994.
We specifically dealt with this time period in Goettee I and
concluded that respondent’s prioritizations in the settings in
which they occurred did not constitute ministerial acts and so
petitioners were not entitled to any relief. Petitioners direct
our attention to Jacobs v. Commissioner, T.C. Memo. 2000-123. In
contrast to Jacobs, the record in the instant case includes
substantial evidence as to what happened, when, and why, as to
this time period. Petitioners have not presented anything
(evidence, caselaw, or other) warranting reconsideration of our
Goettee I rejection of this contentions.
4. Section 6601(c).2
Petitioners raise on this motion, for the first time,
section 6601(c) as a basis for arguing that additional time
periods should be abated because of respondent’s delay in
assessing the liabilities.
2 Unless indicated otherwise, all section references are to
sections of the Internal Revenue Code of 1986 as in effect for
proceedings commenced at the time the petition in the instant
case was filed.
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