Deborah K. Skyrms - Page 2

                                        - 2 -                                         
               Respondent determined additions to petitioner's Federal                
          income tax for the years 1979 through 1982 as follows:                      
          Additions to Tax                                                            
          Year            Sec. 6653(a)(1)   Sec. 6653(a)(2)1    Sec. 6659             
          1979                 $211            applies          $1,266                
          1980                  189            applies           1,137                
          1981                   22            applies             131                
          1982                  221            applies             742                
                                                                                     
                                                                                     
               1. Fifty percent of the interest due on the portion of the             
          underpayment attributable to negligence for the years 1979, 1980,           
          1981, and 1982.                                                             

               In a Stipulation of Settled Issues the parties agree that              
          "all issues that relate to the additions to tax" have been                  
          conceded except liability for the negligence additions to tax for           
          the taxable years 1979 through 1982 and the applicability of                
          section 6659 "for the taxable year 1981."  The stipulation                  
          limiting the contest of the application of section 6659 to the              
          1981 year is by way of a handwritten addendum to paragraph 2 of             
          the stipulation agreement.  At trial, respondent's counsel read             
          into the record the stipulated paragraph with the added language.           
          Although petitioner's counsel made a correction to the reading of           
          the paragraph, it was not with respect to the language addressing           
          the year of the 6659 addition.2                                             
               In view of the record, we interpret paragraph 2 of the                 
          stipulation of settled issues as a concession by petitioner of              


          2On brief, petitioner addressed the sec. 6659 addition only                 
          as it relates to the year 1981.                                             




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