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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 for
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