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motion similar to petitioners' motion); see also Gollin v.
Commissioner, T.C. Memo. 1996-454; Grelsamer v. Commissioner,
T.C. Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398.
Counsel for petitioners seek to raise a new issue long after
the trial of these consolidated cases. Resolution of such issue
might well require a new trial. Such a further trial "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 consolidated
cases, petitioners' motion for leave is not well founded.
Farrell v. Commissioner, supra.
Even if petitioners' motion for leave were granted, the
arguments set forth in the motion and the attached memorandum
lodged with this Court are invalid, and the motion would be
denied. Therefore, and for reasons set forth in more detail
below, petitioners' motion for leave shall be denied.
Some of our discussion of background and circumstances
underlying petitioners' motion 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-
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