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First, petitioner asserts that we misinterpreted the case
law in support of our holding that Mr. Berg’s failure to attach
petitioner’s copy of the joint notice of deficiency to the
unauthorized petition did not invalidate the petition. In
particular, petitioner alleges that we misread Normac, Inc. v.
Commissioner, 90 T.C. 142 (1988); O’Neil v. Commissioner, 66 T.C.
105 (1976); and Estate of DuPuy v. Commissioner, 48 T.C. 918
(1967). We have previously rejected petitioner’s legal arguments
on this issue, not only in Martin II, but also in a prior
proceeding that arose out of Martin I. See Rothhammer v.
Commissioner, T.C. Memo. 2001-46. A motion for reconsideration
is not the appropriate forum for rehashing these arguments. See
Estate of Quick v. Commissioner, supra at 441-442.
Second, petitioner challenges our application of Eversole v.
Commissioner, 46 T.C. 56 (1966), to the limitations period issue.
Petitioner argues that Martin II distinguished the facts in
Eversole from petitioner’s case and improperly treated Mr. Berg’s
filing of the petition as authorized. On the contrary, Martin II
treated the petition as unauthorized and addressed petitioner’s
attempt in his reply brief to distinguish Eversole from Martin II
by emphasizing the close relationship between the unauthorized
filer and the taxpayer in Eversole.
III. Conclusion
We have considered petitioner’s remaining arguments and, to
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