Robert D. Grossman, Jr. - Page 9

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          matters if these matters are resolved in petitioner’s favor in              
          petitioner’s dockets.                                                       
               The clear textual presence of an agreement to give Betsy the           
          benefit of certain possible successes by petitioner and the clear           
          textual absence of an agreement to give petitioner any benefit of           
          any successes by Betsy bolsters our conclusion that the text of             
          the stipulations in Betsy’s dockets does not contain any hidden             
          or implied benefits for petitioner.                                         
               Petitioner maintains that:                                             

               Here, Respondent, with full knowledge that Petitioner was              
               covered by the same notices of deficiency, entered into the            
               agreements with Betty Grossman which, by their plain and               
               unambiguous terms and without limitation, conceded certain             
               adjustments ‘with respect to’ Petitioner’s deficiency                  
               notice.                                                                
          We read the stipulations of settled issues in Betsy’s dockets as            
          dealing with, or providing rules for resolution of, only Betsy’s            
          liabilities with respect to the notices of deficiency, with                 
          petitioner’s liabilities being referred to only insofar as Betsy            
          and the Commissioner agreed was appropriate in determining                  
          Betsy’s liabilities.  Thus, we do not read the stipulations of              
          settled issues in Betsy’s dockets as providing any concessions              
          with regard to petitioner’s liabilities for the section 6653(b)             
          addition for 1986 or the section 6661 addition for 1985.                    
               Petitioner contends that we should prevent respondent from             
          taking inconsistent positions in his and Betsy’s cases;                     





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