Opinion
22935-18W
01-30-2023
DON HOU, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 19, 2023, petitioner filed a Motion for Reconsideration of Order. In petitioner's motion, petitioner seeks reconsideration of the Court's Order and Order of Dismissal for Lack of Jurisdiction, entered January 12, 2023.
The disposition of a motion to reconsider, vacate or revise a decision rests within this Court's discretion. See, e.g., Vaughn v. Commissioner, 87 T.C. 164, 166-167 (1986). A motion to reconsider or to vacate typically is not granted in the absence of substantial error or unusual circumstances, such as mistake, inadvertence, surprise, excusable neglect, newly discovered evidence, or fraud. Knudsen v. Commissioner, 131 T.C. 185 (2008); Brannon's of Shawnee, Inc. v. Commissioner, 69 T.C. 999 (1978). None of those factors appear present in this case. Petitioner's motion for reconsideration does not persuade us otherwise.
Upon due consideration of the foregoing, it is
ORDERED that petitioner's Motion for Reconsideration of Order is denied.