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adjustment sought by petitioners is not addressed in the
stipulation and is not computational in nature. The stipulation
agreement 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 it 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 in the stipulation, and
petitioners must live with both its benefits and burdens.
Respondent requests that the Court impose against
petitioners and their counsel a penalty pursuant to section
6673(a)(1) and (2). In support of this request, respondent
contends that petitioners advanced arguments primarily for the
purpose of delaying entry of decision. In the exercise of our
discretion, we shall not grant respondent's request.
To reflect the foregoing,
An appropriate order will
be issued granting
respondent's motion for
entry of decision, and
decision will be entered
accordingly.
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Last modified: May 25, 2011