- 4 - 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 alsoPage: Previous 1 2 3 4 5 6 Next
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