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of negotiation, each party agrees to concede rights that may be
asserted against his or her adversary as consideration for those
secured in the agreement. Saigh v. Commissioner, 26 T.C. 171,
177 (1956). We enforce settlement stipulations unless justice
requires otherwise. Adams v. Commissioner, 85 T.C. 359, 375
(1985); Saigh v. Commissioner, supra. We also enforce
stipulations where the parties agree to be bound by the outcome
of a test case. Hillman v. Commissioner, T.C. Memo. 1982-468.
In determining the proper meaning of the terms of settlement, we
look to the language of the stipulation and the circumstances
surrounding its execution. Robbins Tire & Rubber Co. v.
Commissioner, 52 T.C. 420, 435-436 (1969).
Petitioners request that we instruct respondent to prepare a
decision document that incorporates several noncomputational
adjustments. We decline this invitation. The adjustments sought
by petitioners are not addressed in the stipulation agreement and
involve issues that are not now before the Court. The
stipulation is clear and shows that the parties agreed to resolve
this case in the manner set forth therein. It was incumbent upon
petitioners' counsel to understand the significance of the
stipulation before agreeing to its content on behalf of
petitioners. The stipulation was voluntarily entered into and
must be given binding effect. The interests of justice do not
require otherwise. The parties struck a bargain, and petitioners
must live with its benefits and burdens.
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