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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-
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