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C. Certification for Appeal
Petitioner asks us to certify this case for immediate appeal
if we do not grant his motion. We decline to do so.
We will certify an interlocutory order for an immediate
appeal if we conclude that (1) a controlling question of law is
present, (2) substantial grounds for difference of opinion are
present, and (3) an immediate appeal from the order may
materially advance the ultimate termination of the litigation.
Sec. 7482(a)(2)(A); Rule 193. Failure to meet any one of the
three requirements is grounds for denial of certification.
General Signal Corp. & Subs. v. Commissioner, 104 T.C. 248, 251
(1995); Kovens v. Commissioner, 91 T.C. 74, 77 (1988), affd.
without published opinion 933 F.2d 1021 (11th Cir. 1991). Only
exceptional circumstances justify a departure from the policy of
postponing appellate review until after entry of final judgment.
Coopers & Lybrand v. Livesay, 437 U.S. 463, 475 (1978);
Klinghoffer v. S.N.C. Achille Lauro, 921 F.2d 21, 25 (2d Cir.
1990); General Signal Corp. & Subs. v. Commissioner, supra at
251.
Petitioner has not stated reasons for us to certify this
case for interlocutory appeal. There is not a substantial ground
for difference of opinion as to the question of law present in
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