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his documents several years earlier. Shortly after trial, on
January 24, 2006, petitioner filed a motion to reopen the record
in order to submit evidence of his marriage.4
Respondent contends that this Court should deny petitioner’s
motion because respondent had requested the evidence from
petitioner, and petitioner had numerous chances to provide the
evidence prior to and at trial and repeatedly refused and failed
to do so. In the alternative, respondent requests that, if this
Court grants petitioner’s motion, respondent be allowed
additional time to subpoena petitioner’s spouse’s son to prove
that petitioner’s spouse has her own income and cannot be claimed
as petitioner’s dependent.5 We deny petitioner’s motion to
reopen the record to admit the evidence because it is the policy
of the Court to try all of the issues raised in a case in one
proceeding to avoid piecemeal and protracted litigation. Haft
Trust v. Commissioner, 62 T.C. 145, 147 (1974), vacated 510 F.2d
43 (1st Cir. 1975). Petitioner was given ample opportunity to
4Specifically, petitioner sought to introduce a marriage
certificate and his spouse’s Social Security number.
5In petitioner’s motion he states that, because he was so
angered by respondent’s refusal to accept his word as proof of
his marital status, he forgot that he was able to provide the
requested information. Petitioner further states that he
retrieved his spouse’s Social Security number from her son who
handles all her banking. Petitioner also states that his wife
receives Social Security income. Respondent cites sec. 151(b)
and Turner v. Commissioner, T.C. Memo. 2004-251, for the
proposition that any income petitioner’s spouse receives, however
small, bars petitioner from claiming his spouse as a dependent.
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