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surrounding its execution. Robbins Tire & Rubber Co. v.
Commissioner, 52 T.C. 420, 435-436 (1969).
Petitioners ask the Court to instruct respondent to prepare
a decision document that incorporates several noncomputational
adjustments. We decline to do so. The adjustments sought by
petitioners are not addressed in the stipulation 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 it 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 in the stipulation, and petitioners must live
with both 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