- 4 - to the established policy of this Court to try all issues raised in a case in one proceeding and to avoid piecemeal and protracted litigation." Markwardt v. Commissioner, 64 T.C. 989, 998 (1975); see also Robin Haft Trust v. Commissioner, 62 T.C. 145, 147 (1974). Consequently, under the circumstances here, at this late date in the litigation proceedings, long after trial and briefing, and after the issuance of numerous opinions on issues and facts closely analogous to those in this case, we consider that the practice of this Court would support, if not absolutely require, denial of petitioners' motion for leave. However, we do not rely solely on such procedural matters for denying petitioners' motion for leave. Instead, we also have considered the consequences of granting such motion. We conclude that even if petitioners' motion for leave were granted, the arguments set forth in petitioners' motion for decision and attached memorandum, lodged with this Court, are without merit and such motion would be denied. Therefore, and for reasons set forth in more detail below, petitioners' motion for leave will be denied. 2. Facts and Circumstances Relevant to Petitioners' Proposed Motion for Decision In a notice of deficiency dated August 25, 1989, respondent determined a deficiency in petitioners' Federal income tax forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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