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adjustments. On December 30, 1986, Mr. DeCastro executed a
stipulated decision on behalf of petitioners that states as
follows:
DECISION
Pursuant to agreement of the parties in the above-
entitled case, it is
ORDERED AND DECIDED: That there is a deficiency
in income tax due from the petitioners for the taxable
year 1978 in the amount of $23,000.00;
That there are no additions to the taxes due from
the petitioners for the taxable year 1978, under the
provisions of I.R.C. sec. 6653(a); and
That there are no additions to the taxes due from
the petitioners for the taxable year 1978, under the
provisions of I.R.C. sec. 6621(d).
On the same date, Mr. DeCastro mailed a check to Mr. McWade,
signed by petitioners and made payable to the IRS in the amount
of $53,571, representing $23,000 in tax and $30,571 in interest.
Mr. McWade executed the stipulated decision on April 27, 1987,
and mailed the document to the Court.
On March 30, 1987, Mr. McWade filed a Motion to Sever
petitioners' case from docket No. 17445-82. Shortly thereafter,
the Court granted the motion, severed petitioners' case from
docket No. 17445-82, and assigned the case docket No. 8922-87.
On May 8, 1987, the Court entered the parties' stipulated
decision as described above in docket No. 8922-87.
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