T.C. Memo. 1996-359                                  
                               UNITED STATES TAX COURT                                
                     ROGER W. AND KATHLEEN STOY, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 24961-87.                   Filed August 6, 1996.           
               Larry Kars, for petitioners.                                           
               Cheryl B. Harris, for respondent.                                      
                                 MEMORANDUM OPINION                                   
               WRIGHT, Judge:  This matter is before the Court on                     
          respondent's motion for entry of decision in accordance with a              
          stipulation of settlement (the stipulation) filed October 11,               
          1994.  We must decide whether the subject decision should reflect           
          several adjustments that are not reflected in the stipulation.              
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