Gregory Summers and Justine Summers - Page 5

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          606 (1962), affd. 328 F.2d 662 (6th Cir. 1964).  We will enforce            
          a stipulation of settlement, whether filed or orally stipulated             
          into the record, unless justice requires that we do otherwise.              
          Adams v. Commissioner, 85 T.C. 359, 375 (1985); Sennett v.                  
          Commissioner, 69 T.C. 694 (1978); Saigh v. Commissioner, 26 T.C.            
          171, 177 (1956).                                                            
               Petitioners ask the Court to enter a decision that reflects            
          their claim that their 1984 self-employment income equals an                
          amount not shown in the Stipulation.  We refuse to do so.                   
          Whether petitioners incurred their claimed losses, and, if they             
          did, whether the losses were from self-employment, raises new               
          issues that are not before the Court.  Petitioners’ pleadings               
          make no reference to these issues, and the Stipulation is silent            
          with respect thereto.  The Stipulation does not even mention the            
          losses that petitioners now claim to have incurred in 1984.                 
               The Stipulation speaks for itself and shows that the parties           
          agreed to resolve this case in the manner set forth therein.  The           
          Stipulation, voluntarily entered in settlement of this lawsuit,             
          must be given binding effect.  The parties struck a bargain in              
          the Stipulation, and petitioners must live with the benefits and            
          burdens of it.                                                              
               To reflect the foregoing,                                              
                                             An appropriate order will be             
                                        issued granting respondent's motion           






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