- 21 -
note that petitioner could have raised the issue of her
eligibility for relief under that provision in the prior
proceedings in the instant case. We note that TAMRA, which
included the transitional rule, was enacted November 10, 1988,
102 Stat. 3812, well before the instant case was tried. As noted
above, it is the policy of this Court to try all of the issues
raised in a case in one proceeding in order to avoid piecemeal
and protracted litigation. Alexander v. Commissioner, 95 T.C. at
469. In the interest of judicial efficiency, we generally will
not grant a motion for reconsideration to resolve issues that
could have been raised during prior proceedings. CWT Farms, Inc.
v. Commissioner, 79 T.C. 1054, 1057 (1982); Robin Haft Trust v.
Commissioner, 62 T.C. 145, 147 (1974), affd. on this issue, 510
F.2d 43, 45 n.1 (1st Cir. 1975).
17(...continued)
a reading of the transitional rule in conjunction with
section 6013(e) reveals that Congress did intend for
the transitional rule to provide broader innocent
spouse relief under limited circumstances to a certain
class of spouses--i.e., those who filed joint returns
with substantial understatements prior to January 1,
1985, and whose marriages had since terminated. See
Thompson, 63 T.C.M. (CCH) at 2884. For such spouses,
Congress eliminated the requirement under section
6013(e)(1)(D), which required a spouse to show that it
would be inequitable to hold her liable for the
understatement. In its place, Congress instituted a
"net worth" test, relieving the spouse from liability
if she met the "no reason to know" requirement and had
a net worth of less than $10,000 immediately after the
termination of the marriage. Thus, under the
transitional rule, unlike under section 6013(e),
Congress afforded innocent spouse relief to a spouse
who had benefitted from an erroneous deduction as long
as after the termination of the marriage her net worth
was less than $10,000.
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