- 85 -- 85 -
Even if petitioners' motions for leave were granted, the
arguments set forth in each of petitioners' motions for decision
and attached memoranda, lodged with this Court, are invalid and
such motions would be denied. Therefore, and for reasons set
forth in more detail below, petitioners' motions for leave shall
be denied.
Some of our discussion of background and circumstances
underlying petitioners' motions is drawn from documents submitted
by the parties and findings of this Court in two earlier
decisions. See Estate of Satin v. Commissioner, T.C. Memo. 1994-
435; Fisher v. Commissioner, T.C. Memo. 1994-434. Such matters
are not disputed by the parties. We discuss the background
matters for the sake of completeness. As we have noted, granting
petitioners' motions for leave would require further proceedings.
The Estate of Satin and Fisher cases involved Stipulation of
Settlement agreements (piggyback agreements) made available to
taxpayers in the Plastics Recycling project, whereby taxpayers
could agree to be bound by the results of three test cases:
Provizer v. Commissioner, T.C. Memo. 1992-177, and the two Miller
cases. We held in the Estate of Satin and Fisher cases that the
terms of the piggyback agreement bound the parties to the results
in all three lead cases, not just the Provizer case. Petitioners
assert that the piggyback agreement was extended to them, but
they do not claim to have accepted the offer timely, so they
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