John G. Goettee, Jr. and Marian Goettee - Page 10

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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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