John Sann and Marianne Sann, et al. - Page 86

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          require new trials.  Such further trials "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 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 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             
          the 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.  See Estate of Satin v. Commissioner, T.C. Memo. 1994-           
          435; Fisher v. Commissioner, T.C. Memo. 1994-434.  These matters            
          are not disputed by the parties.  We discuss the background                 
          matters for the sake of completeness.  As we have noted, granting           
          petitioners' motions for leave would require further proceedings.           






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