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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 the trials 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 without merit
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 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
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