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taxes paid by Shell which need to be established in order to
determine the correct amounts attributable to petitioners. To
the extent that petitioners may be questioning only the amounts
allowed by respondent for such taxes in the years before us,
separately from the depletion allowance, we note that no
reference to this point was made in the submission of this case
fully stipulated. Such submission precludes the use of further
evidence by a party absent the consent of the other party and/or
an appropriate order of the Court. Rule 143(b). The fact that
the case was submitted fully stipulated does not relieve
petitioners of their burden of proof as to facts necessary to
sustain their position. See Meunier v. Commissioner, T.C. Memo.
1991-446. While the full impact of petitioners' assertions is
not easily determined, we are satisfied that there are no
extraordinary circumstances which would justify our reopening
this fully stipulated case and ordering a trial.
To the extent that the facts and arguments which petitioners
set forth are directed toward obtaining a decision from us that
Shell withheld too large a portion of windfall profit taxes in
respect of their share of the oil production, we simply have no
jurisdiction to resolve this apparent dispute with Shell.
(7) They seek damages for alleged errors by respondent in
the handling of their tax matters. The simple answer to this
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