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Secured Property, in which AAL reported that it had acquired the
Fitch Property on December 15, 1993. On motions for
reconsideration we do not, except under extraordinary
circumstances, address any new issue which a party could have
addressed but failed to address prior to the Court’s deciding the
case. See, e.g., Stoody v. Commissioner, 67 T.C. 643, 644
(1977). But in any case, the facts in evidence in this case
abundantly demonstrate, as we found, that the Form 1099-A was
erroneous. Furthermore, as we also pointed out in our Memorandum
Opinion, the amended 1994 partnership return emphasized the
partners’ position that the Form 1099-A was erroneous.
Petitioners contend that the factual statement in our
Memorandum Opinion is erroneous in its basic elements.
Essentially, petitioners disagree with the Court’s conclusions
about the facts. In our Memorandum Opinion, we considered and
addressed petitioners’ arguments and all of the documentary
evidence. Petitioners have not shown any manifest error of fact.
On the basis of the record, petitioners’ version of the
“facts” misconstrues the real facts. In essence, in addition to
the “incorrect” Form 1099-A, petitioners’ case is anchored on two
essential documents; namely, the Grant Deed, which was dated
December 15, 1993, and the Covenant Not to Sue, which was also
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