Roger W. and Kathleen Stoy - Page 5

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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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