-6- guidelines and was a reasonable exercise of respondent’s discretion. Petitioners contend that respondent’s rejection of their OIC while a motion for reconsideration was pending before the Court was an abuse of discretion. We disagree. The granting of a motion to reconsider rests in the discretion of the Court. Louisville & Nashville R. Co. v. Commissioner, 641 F.2d 435, 443-444 (6th Cir. 1981), affg. on this issue and revg. on other issues 66 T.C. 962 (1976); Estate of Halas v. Commissioner, 94 T.C. 570, 574 (1990); Vaughn v. Commissioner, 87 T.C. 164, 166-167 (1986). Motions to reconsider will not be granted unless unusual circumstances or substantial error is shown. Estate of Halas v. Commissioner, supra at 574; Vaughn v. Commissioner, supra at 167. Petitioners submitted their offer-in-compromise to respondent on November 15, 2005. However, they failed to respond to respondent’s repeated requests for additional information. In April 2006, petitioners requested an extension until August 15, 2006, so that petitioner could file his 2005 income tax return. The Court was not persuaded that petitioners were entitled to an extension of any deadlines related to respondent’s processing of the OIC and denied their motion. In the interim, respondent rejected petitioners’ OIC. We have no reason to believe that an extension to August would have changed the disposition of petitioners’ offer-in-Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007