Richard R. Reed - Page 4

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          1451, 1455 (1986); see also Jeff D. v. Andrus, 899 F.2d 753,                
          759 (9th Cir. 1989).                                                        
               We will enforce a stipulation of settlement, whether filed             
          or orally stipulated into the record, unless justice requires               
          that we do otherwise.  Adams v. Commissioner, 85 T.C. 359,                  
          375 (1985); Sennett v. Commissioner, 69 T.C. 694 (1978);                    
          Saigh v. Commissioner, 26 T.C. 171, 177 (1956).  In the instant             
          case, justice does not require that we do otherwise.  The record            
          speaks for itself and shows that the parties agreed to resolve              
          this case in the manner set forth therein.  The stipulation of              
          settlement memorialized in the record, voluntarily entered in               
          settlement of this lawsuit, must be given binding effect.  The              
          parties struck a bargain in the stipulation, and petitioner must            
          live with the benefits and burdens of it.                                   
               To reflect the foregoing,                                              
                                             An appropriate order will be             
                                        issued granting respondent's motion           
                                        for entry of decision, and decision           
                                        will be entered in accordance                 
                                        with the respondent’s computation.            












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