- 7 -
were precluded from challenging their underlying tax liabilities
for 1993, 1994, and 1995, and that respondent’s jeopardy levy
would not be withdrawn. The notice of determination does not
expressly address petitioners’ request to sell the stock.
Discussion
The granting of a motion for reconsideration rests within
the Court’s discretion. Estate of Quick v. Commissioner, 110
T.C. 440, 441 (1998); see Lucky Stores, Inc. v. Commissioner,
T.C. Memo. 1997-70, affd. 153 F.3d 964 (9th Cir. 1998). A motion
for reconsideration will be denied absent a showing of unusual
circumstances or substantial error. Estate of Quick v.
Commissioner, supra; see 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, 166-167 (1986).
Whether Application of Section 6335(f) Was an Untimely New Issue
Petitioners cited section 6335(f) only in their reply brief.
Respondent suggests that he therefore lacked adequate opportunity
to present evidence and legal argument regarding the application
of section 6335(f). We disagree. Before, during, and after
trial, petitioners repeatedly raised the claim that respondent
had wrongly refused to comply with their request to liquidate the
seized stock accounts and to give them appropriate credit.5
5 As respondent notes in his motion for reconsideration,
(continued...)
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