- 4 - On July 22, 2002, the Appeals Office issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). In the notice of determination, Appeals Officer Mares determined, among other things, that (1) the limitations period had not expired prior to respondent’s assessment of petitioner’s 1980 income tax liability, and (2) collection by levy was appropriate under the circumstances. Discussion Reconsideration under Rule 161 is intended to correct substantial errors of fact or law and allow the introduction of newly discovered evidence that the moving party could not have introduced, by the exercise of due diligence, in the prior proceeding. Estate of Quick v. Commissioner, 110 T.C. 440, 441 (1998). This Court has discretion whether to grant a motion for reconsideration and will not do so unless the moving party shows unusual circumstances or substantial error. Id.; see also Vaughn v. Commissioner, 87 T.C. 164, 166-167 (1986). “Reconsideration is not the appropriate forum for rehashing previously rejected legal arguments or tendering new legal theories to reach the end result desired by the moving party.” Estate of Quick v. Commissioner, supra at 441-442. I. The Alleged “Material Factual Errors” In his motion for reconsideration, petitioner alleges thatPage: Previous 1 2 3 4 5 6 7 8 Next
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