Opinion
19385-21L
03-14-2023
MEHLEK DAWVEED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Albert G. Lauber Judge
On March 6, 2023, this Court filed its Memorandum Opinion (T.C. Memo. 2023-28), which states at the end thereof: "An appropriate order and decision will be entered." That same day petitioner filed a document captioned "Notice of Objection to Memorandum Opinion." We will recharacterize that filing as a Motion for Reconsideration of Findings of Opinion Pursuant to Rule 161. On March 7, 2023, petitioner filed a document captioned Motion for Reconsideration and separately filed on March 9, 2023, an Exhibit to that Motion. We will recharacterize those filings as petitioner's Second Motion for Reconsideration of Findings or Opinion Pursuant to Rule 161. In both Motions petitioner repeats the arguments he previously made. "Reconsideration is not the appropriate forum for rehashing previously rejected legal arguments or tendering new legal theories to reach the end result desired by the moving party." Estate of Quick v. Commissioner, 110 T.C. 440, 442 (1998). It is accordingly
ORDERED that petitioner's Motion for Summary Judgment, filed September 26, 2022 (as supplemented on November 29, 2022), is denied. It is further
ORDERED that respondent's Cross-Motion for Summary Judgment, filed October 3, 2022, is granted. It is further
ORDERED that petitioner's Notice of Objection to Memorandum Opinion, filed March 6, 2023, is recharacterized as petitioner's Motion for Reconsideration of Findings of Opinion Pursuant to Rule 161. It is further
ORDERED that petitioner's Motion for Reconsideration, filed March 7, 2023, is recharacterized as petitioner's Second Motion for Reconsideration of Findings of Opinion Pursuant to Rule 161. It is further
ORDERED that petitioner's First and Second Motions for Reconsideration are denied. It is further
ORDERED and DECIDED that the determinations set forth in the Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, dated July 29, 2021, upon which this case is based, are sustained in full.