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City, Oklahoma, and was tried on June 1, 1994. At the conclusion
of the trial, the parties agreed to defer the setting of post-
trial briefing dates in order to await the outcome of the earlier
case1 already under consideration by another division of this
Court. The parties in this case stipulated to a substantial
portion of the facts and proffered only a limited amount of
testimony. The parties believed that they could agree to be
bound by the outcome of El Charro I, but presented their evidence
in the event that factual distinctions were found in that case.
The earlier case involves three cases that had been consolidated
for trial. El Charro TV Rental, Inc. (El Charro), is one of the
participating entities involved in the earlier consolidated
cases. Petitioner’s 2 taxable years prior to those before the
Court in this case are the subject of El Charro I. It was
thought that an opinion in El Charro I could obviate the need for
briefing and an opinion in this case.
Following an opinion in El Charro I, the parties contacted
the Court and advised that an agreement had been reached to
settle all issues in this case subject to the outcome of
petitioner's appeal of El Charro I. On June 15, 1995, the
1 For purposes of this opinion, the earlier case is referred
to as "El Charro I". ABC Rentals of San Antonio, Inc. v.
Commissioner, T.C. Memo. 1994-601, affd. without published
opinion sub nom. El Charro TV Rental, Inc. v. Commissioner, 79
F.3d 1145 (5th Cir. 1996), and revd. and remanded 97 F.3d 392
(10th Cir. 1996).
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