Gregory Summers and Justine Summers - Page 4

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               Respondent submitted to the Court a decision document (the             
          Document) that she claims is in accordance with the Stipulation.            
          By Order dated November 30, 1995, the Court directed petitioners            
          to respond to the Document.  Petitioners allege in their response           
          that the 1984 self-employment tax shown in the Document is wrong.           
          Petitioners allege in their response that their 1984                        
          self-employment income equals the $41,857 of receipts shown in              
          the Stipulation, less:  (1) A $3,351 loss from Summit Equities,             
          (2) a $31,562 loss from Diamond Leasing, and (3) a $2,567 loss              
          from AIG Investors.  Petitioners allege in their response that              
          Gregory Summers “rendered substantial personal services“ to these           
          three entities.                                                             
                                     Discussion                                       
               The compromise and settlement of tax cases is governed by              
          general principles of contract law.  A settlement stipulation is            
          in essence a contract.  Each party agrees to concede some rights            
          which he or she may assert against his or her adversary as                  
          consideration for those secured in the settlement agreement.                
          Saigh v. Commissioner, 26 T.C. 171, 177 (1956).  Like contracts,            
          stipulations of settlement bind the parties thereto to the terms            
          thereof.  Stamos v. Commissioner, 87 T.C. 1451, 1455 (1986).  In            
          determining the proper meaning of the terms, we look to the                 
          language of the stipulation and the circumstances surrounding its           
          execution.  Robbins Tire & Rubber Co. v. Commissioner, 52 T.C.              
          420, 435-436 (1969); see also Brink v. Commissioner, 39 T.C. 602,           




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