- 94 - 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.Page: Previous 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94
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