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with attachments, and memoranda in support of such motions.
Respondent filed objections, with attachments, and memoranda in
support thereof, and petitioners thereafter filed reply
memoranda. Petitioners Gollin and Fishbach argue that they
should be afforded the same settlement that was reached between
other taxpayers and the IRS in docket Nos. 10382-86 and 10383-86,
each of which was styled Miller v. Commissioner. See Farrell v.
Commissioner, T.C. Memo. 1996-295 (denying a motion similar to
petitioners' motions); see also Grelsamer v. Commissioner, T.C.
Memo. 1996-399 and Zenkel v. Commissioner, T.C. Memo. 1996-398.
For convenience, in this subsection hereafter references to
"petitioners" shall be limited to petitioners Gollin and
Fishbach.
Counsel for petitioners seek to raise a new issue long after
the trials in these cases. Resolution of such issue might well
require new trials. Such further trials "would be contrary 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 these cases, petitioners' motions
for leave are not well founded. Farrell v. Commissioner, supra.
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