Robert D. Grossman, Jr. - Page 7

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               In Dorchester Indus. Inc. v. Commissioner, 108 T.C. at 330,            
          we stated, quoting Manko v. Commissioner, T.C. Memo. 1995-10,               
          that:                                                                       
                    For almost a century, it has been settled that                    
               voluntary settlement of civil controversies is in high                 
               judicial favor.  Williams v. First Natl. Bank, 216 U.S. 582,           
               595 (1910); St. Louis Mining & Milling Co. v. Montana Mining           
               Co., 171 U.S. 650, 656 (1898).  A valid settlement, once               
               reached, cannot be repudiated by either party, and after the           
               parties have entered into a binding settlement agreement,              
               the actual merits of the settled controversy are without               
               consequence.  This Court has declined to set aside a                   
               settlement duly executed by the parties and filed with the             
               Court in the absence of fraud or mutual mistake.  Stamm                
               Intl. Corp. v. Commissioner, 90 T.C. 315 (1988); Spector v.            
               Commissioner, 42 T.C. 110 (1964).  However, a court will not           
               force a settlement on parties where no settlement was                  
               intended.  Autera v. Robinson, 419 F.2d 1197 (D.C. Cir.                
               1969).                                                                 
               When we examine the language used and the surrounding                  
          circumstances, we see that the stipulations of settled issues in            
          Betsy’s dockets are styled “Betsy S. Grossman, Petitioner” and              
          show the docket numbers of Betsy’s dockets in the headings; they            
          do not show petitioner’s name or the docket numbers of his cases            
          in their headings.  Although Betsy’s petitions result from joint            
          notices of deficiency, Betsy’s dockets deal only with Betsy’s               
          deficiencies and not with petitioner’s deficiencies.  The                   
          stipulations of settled issues in Betsy’s dockets purport to be             
          agreements between the parties in those dockets; petitioner is              
          not and never was a party in those dockets.                                 
               In the context of the foregoing, the simplest and most                 
          direct interpretation of Betsy’s and the Commissioner’s                     




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