Philippe and Nadine Grelsamer - Page 73

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          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.            
               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.  Such matters are not disputed by the parties.  See              
          Estate of Satin v. Commissioner, T.C. Memo. 1994-435; Fisher v.             
          Commissioner, T.C. Memo. 1994-434.  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 Estate of Satin and Fisher 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               




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