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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 that
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Last modified: May 25, 2011