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The granting of a motion for reconsideration rests within
the discretion of the Court. Estate of Quirk v. Commissioner,
928 F.2d 751, 759 (6th Cir. 1991), affg. in part and remanding in
part T.C. Memo. 1988-286; Klarkowski v. Commissioner, 385 F.2d
398, 401 (7th Cir. 1967), affg. T.C. Memo. 1965-328; see Con-
cordia Coll. Corp. v. W.R. Grace & Co., 999 F.2d 326, 330 (8th
Cir. 1993). A motion for reconsideration will be denied unless
unusual circumstances or substantial error is shown. Estate of
Quirk v. Commissioner, supra; Alexander v. Commissioner, 95 T.C.
467, 469 (1990), affd. without published opinion sub nom. Stell
v. Commissioner, 999 F.2d 544 (9th Cir. 1993); Vaughn v.
Commissioner, 87 T.C. 164, 167 (1986).
With respect to petitioner’s argument that the Court incor-
rectly concluded that respondent impeached the testimony of Mr.
Ankerfelt, petitioner asserts:
The Opinion incorrectly concluded that Gary
Ankerfelt’s credibility was impeached because the
affidavit he submitted in a workers’ compensation case
involving Hix Trucking, a TLC customer, was contrary to
his testimony at trial. A witness may be impeached
only by a prior inconsistent statement. Here, however,
Mr. Ankerfelt made no prior inconsistent statement; his
testimony was consistent with his prior statement.
* * * In any event, Mr. Ankerfelt’s testimony was
credible; his testimony on every point was corroborated
by other witnesses.
On the record before us, we reject petitioner’s argument.
At the trial in this case, Mr. Ankerfelt testified with
respect to TLC’s role in hiring, firing, and assigning projects
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