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sections 6653(a)(1)(A) and (B) or 6661 for that year. The
stipulated decision includes the parties' stipulation that the
deficiency in tax was computed on the assumption that petitioners
correctly reported Irving & Co. partnership items on their 1986
tax return and that adjustments to petitioners' tax liability for
1986 relating to their investment in Irving & Co. would be
resolved in separate partnership level proceedings. The final
paragraph of the stipulation states that, upon entry of decision,
petitioners waive the restriction contained in section 6213(a)
prohibiting assessment and collection of the deficiency and
statutory interest until the decision of the Court is final.
On July 11, 1991, petitioners paid $1,747 to respondent in
satisfaction of the deficiency stipulated to in docket No. 11547-
90. Further, on July 18, 1991, petitioners paid $976.38 to
respondent in satisfaction of the interest due on the deficiency.
The latter payment resulted in an overpayment of $17.41, which
respondent credited to petitioners' tax liability for 1988
pursuant to section 6402(a).
On April 16, 1993, petitioner, acting as tax matters partner
for Irving & Co., filed a timely petition for readjustment with
the Court, assigned docket No. 7530-93, seeking readjustment of
items set forth in a notice of final partnership administrative
adjustment (FPAA) issued to Irving & Co. for its taxable year
1986. On September 12, 1994, the Court entered a decision
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