Vincent and Clotilde Farrell, Jr. - Page 4

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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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