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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.
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