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negotiations, or whether he attempted to resolve with Mr. McWade
the discrepancy between the $67,972.50 of Kersting interest
deductions disallowed by the notice of deficiency and the lower
amount of $38,523 alleged by the petition as having been claimed
on the return, petitioners did agree to a deficiency
substantially less than that determined by respondent.
In sum, the stipulated decision that Mr. DeCastro executed
on petitioners' behalf is now final, and petitioners have failed
to persuade us that the notice of deficiency issued to them is
invalid. It follows that we lack jurisdiction to vacate the
decision in this case.
To reflect the foregoing,
An order will be issued
denying petitioners' Motion for
Leave to File Motion to Vacate
Decision.
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