Alfred J. Martin - Page 4

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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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