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Petitioners Albert and Louise Churik claim that their
deficiency notice does not reflect their pro rata share of a
partnership deduction that stems from a guaranteed payment and
fails to account properly for a sales tax deduction. Petitioners
John and Susan Ross claim that their notice of deficiency does
not reflect their pro rata share of a partnership deduction that
stems from a guaranteed payment, does not reflect income-
averaging, fails to account properly for a sales tax deduction,
and fails to account accurately for an investment tax credit in
1981.
By Order dated April 16, 1996, the Court directed respondent
to address petitioners' above-referenced response. On June 10,
1996, respondent filed her response. Respondent principally
argues that petitioners are bound by the stipulation agreement,
and the objections raised in petitioners' above-referenced
response amount to issues that are not now before the Court.
Respondent, however, concedes petitioners John and Mary Anne
Antoine's claim to a sales tax deduction. Respondent also
concedes petitioners John and Susan Ross' arguments regarding the
investment tax credit and the sales tax deduction.
Discussion
The general principles of contract law govern the compromise
and settlement of tax cases. In essence, settlement stipulations
are contracts, and this Court is bound to enforce them. Stamos
v. Commissioner, 87 T.C. 1451, 1454 (1986). During the process
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