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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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