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correct substantial errors of fact or law, or to allow newly
discovered evidence to be introduced that could not have been
introduced before the filing of an opinion even if the moving
party had exercised due diligence. Estate of Quick v.
Commissioner, 110 T.C. 440 (1998); Estate of Halder v.
Commissioner, T.C. Memo. 2003-284. The granting of a motion for
reconsideration rests within the discretion of the Court, and
petitioners must show unusual circumstances or substantial error
for their motion to be granted. Estate of Quick v. Commissioner,
supra, at 441. Moreover, we have held that reconsideration is
not the appropriate vehicle for rehashing previously rejected
legal arguments or tendering new legal theories to reach the end
result desired by the moving party. Id. at 441-442.
Petitioners allege that the factual conclusions reached by
the Court in its Memorandum Opinion are incomplete, incorrect,
and not supported by the evidence. We disagree. Furthermore,
all but one of the legal issues raised in the Motions have been
raised by petitioners in their original and reply briefs.
Petitioners assert for the first time that section 6201(d)
places the burden on respondent for producing reasonable and
probative information concerning respondent’s assertion of the
incorrectness of the Form 1099-A, Acquisition or Abandonment of
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