Gregory Summers and Justine Summers - Page 1

          T.C. Memo. 1996-17                                                          

                               UNITED STATES TAX COURT                                

                 GREGORY SUMMERS AND JUSTINE SUMMERS, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16175-93.              Filed January 22, 1996.              

                    Before trial, the parties negotiated a settlement                 
               specifying the manner of resolving this case.  Ps now                  
               seek to raise an issue as to the amount of income                      
               subject to self-employment tax.  This issue was not                    
               raised or preserved by Ps in the pleadings or the                      
               stipulated settlement agreement.  Held:  The issue                     
               raised by Ps is a new issue that is not before the                     

               Michael Weitzner, for petitioners.                                     
               James B. Biagi, for respondent.                                        

                                 MEMORANDUM OPINION                                   
               LARO, 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 June 13, 1994.            
          We must decide whether the subject decision should reflect less             
          self-employment tax than determined by respondent.  We hold that            

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