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sion documents that were executed by the respective counsel for
petitioners and respondent.1 On September 4, 1996, the Court
entered a decision in this case pursuant to the agreement of the
parties.
After the decision in this case was entered for the years at
issue, petitioners and respondent signed on September 6 and
October 17, 1996, respectively, a closing agreement with respect
to petitioners' taxable years 1979 and 1980 (closing agreement).
The closing agreement set forth the agreement of petitioners and
respondent (1)(a) that petitioners have a Federal income tax
liability for their taxable year 1979 in the amount of $1,855,
which was assessed and paid in full, and (b) that there is no
deficiency in Federal income tax due from, or overpayment due to,
petitioners for that year; and (2)(a) that petitioners have a
Federal income liability for their taxable year 1980 in the
amount of $92,744 and (b) that there is an overpayment in Federal
income tax due them for that year in the amount of $141,335.
Discussion
The Court's decision in this case was entered on September
4, 1996. No notice of appeal or timely motion to vacate or
revise the decision was filed in this case, see sec. 74832 and
1 Consequently, the Court denied respondent's motion for entry
of decision as moot.
2 All section references are to the Internal Revenue Code in
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