Harvey M. Pert, Transferee - Page 15

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          5.   Stipulated Settlement Decision for 1987                                
               Petitioner concedes that Kathleen Pert, in her capacity as             
          personal representative of the Estate of Timothy Riffe, agreed to           
          a stipulated decision that Timothy Riffe, deceased, was liable              
          for deficiencies and additions to tax for negligence and                    
          substantial understatement of tax for 1987.  Petitioner also                
          concedes that Kathleen Pert agreed to a stipulated decision that            
          established her tax liabilities for 1987.  Petitioner also                  
          concedes that liabilities were assessed by respondent pursuant              
          to such agreement.                                                          
               Petitioner argues that he may relitigate the liability                 
          of Timothy Riffe, deceased, and Kathleen Pert for 1987.  We                 
          disagree.  As we stated in par. 3 above, res judicata bars a                
          transferee from relitigating the income tax liabilities of a                
          transferor once a final decision has been entered by the Tax                
          Court in the transferor's case, if the decision was stipulated.             
          Krueger v. Commissioner, 48 T.C. at 829-830; Baptiste v.                    
          Commissioner, 29 F.3d 1533 (11th Cir. 1994); Forehand v.                    
          Commissioner, supra; see Huddleston v. Commissioner, 100 T.C. 17            
          (1993).                                                                     
               Petitioner acknowledges that Baptiste v. Commissioner,                 
          supra, and Krueger v. Commissioner, supra, hold that petitioners            
          are bound by the stipulated decision signed by the Estate of                
          Timothy Riffe.  Petitioner acknowledges that, unless we                     
          reconsider our previous decisions on this issue, res judicata               



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