Jean Mathia and Estate of Doyle V. Mathia, Deceased, Jean Mathia, Personal Representative - Page 6

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          moves for relief from the disputed stipulations because they                
          “include legal conclusions which are erroneous” and “so that the            
          record is consistent and accurate”.  On June 5, 2006, petitioners           
          filed a response opposing the motion.  Neither party requested a            
          hearing on respondent’s motion, and we are satisfied that a                 
          hearing is not necessary to rule on the motion.                             
                                     Discussion                                       
               The stipulation process is considered “the bedrock of Tax              
          Court practice” and acts “as an aid to the more expeditious trial           
          of cases”.  Branerton Corp. v. Commissioner, 61 T.C. 691, 692               
          (1974).  Stipulations eliminate burdensome and unnecessary                  
          discovery and result in “an orderly trial with a full and fair              
          exposition of the facts.”  Teller v. Commissioner, T.C. Memo.               
          1992-402.  Stipulations narrow controversies to their essential             
          issues of dispute, Estate of Quirk v. Commissioner, 928 F.2d 751,           
          759 (6th Cir. 1991), affg. in part and remanding in part T.C.               
          Memo. 1988-286, and materially assist a court in managing its               
          caseload, see Stamos v. Commissioner, 87 T.C. 1451, 1456 (1986).            
               Generally, a stipulation of fact is binding on the parties,            
          and the Court is bound to enforce it.  Rule 91; Stamos v.                   
          Commissioner, supra at 1454.  Rule 91(e) provides an exception by           
          permitting relief from the binding effect of a stipulation where            
          justice so requires.  Courts generally enforce stipulations                 
          unless “manifest injustice” would result.  Bokum v. Commissioner,           






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