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Background
On March 16, 1995, respondent issued a notice of deficiency
(notice) to petitioners that determined a deficiency in, and
additions to, their Federal income tax for each of the years
1978, 1981, 1982, and 1983 (years at issue). On June 19, 1995,
petitioners timely filed a petition. This case was calendared
for trial at the Court's trial session in New York, New York,
that began on June 17, 1996. On that date, a stipulation of
settlement (stipulation of settlement) executed by the respective
counsel for petitioners and respondent was filed in this case,
and 30 days, until July 17, 1996, were requested, and granted by
the Court, within which to submit stipulated decision documents.
The stipulation of settlement stated, inter alia: "THE PARTIES
AGREE TO THIS STIPULATION OF SETTLEMENT WHICH RESOLVES ALL OF THE
ISSUES IN THIS CASE."
On July 9, 1996, respondent provided petitioners with compu-
tations reflecting the stipulation of settlement. On July 30,
1996, the Court issued an order in which it directed the parties
to submit stipulated decision documents to the Court or otherwise
file appropriate motions with the Court on or before August 15,
1996. On August 15, 1996, respondent filed a motion for entry of
decision in this case (respondent's motion for entry of decision)
to which the Court ordered petitioners to respond by September 5,
1996. On September 3, 1996, the Court received stipulated deci-
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Last modified: May 25, 2011