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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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