Robert K. and Dawn E. Lowry - Page 4

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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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