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question because respondent is not able to review the methods and
assumptions underlying petitioners' actuary's work inasmuch as
petitioners did not supply sufficient information and they did
not reconcile the actuarial information presented at trial with
the annual statements of Parthenon and PCIC. We view
respondent's substantiation argument as a separate issue from
whether Mr. Merlino's adjustments are correct, and, thus, that
position is contrary to the parties' stipulation. In the Tax
Court, a stipulation is treated as a conclusive admission by the
parties, and the Court will not permit a party to change or
contradict a stipulation, except in extraordinary circumstances.
Rule 91(e); Jasionowski v. Commissioner, 66 T.C. 312, 318 (1976).
We find no extraordinary circumstances present here to cause us
to disregard the stipulation. Accordingly, we do not address
respondent's argument that petitioner failed to provide
sufficient information or to reconcile the actuarial information
presented at trial with the annual statements of Parthenon and
PCIC.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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