William Whelpley, Jr. - Page 16

                                        - 16 -                                         
             indebtedness income in 1988.  Each petitioner filed a                     
             petition in this Court contesting respondent's                            
             determination.  See Whelpley v. Commissioner, docket No.                  
             5394-95 (William and Sara G. Whelpley); Whelpley v.                       
             Commissioner, docket No. 5463-95 (William Whelpley, Jr.).                 
             References to the related cases are to these cases.                       
                  Thereafter, the related cases were set for trial.                    
             Shortly before the trial of those cases, the parties                      
             filed a stipulation of settled issues which states in                     
             part as follows:                                                          

                  the parties reached a basis of settlement with                       
                  respect to the taxable year 1988 as follows:                         
                       b.  If the Court determines the $103,693.00                     
                  was a loan to WAI in 1987, WAI received a                            
                  discharge of indebtedness of $103,693.00 from                        
                  Weeden during 1988.                                                  
                       *    *    *    *    *    *    *                                 
                       e.  The parties agree to be bound by the                        
                  trial record established through oral testimony,                     
                  stipulated facts with exhibits, and exhibits                         
                  introduced by the parties at trial with respect                      
                  to Docket Numbers 21644-93 and 21690-93.                             















Page:  Previous  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  Next

Last modified: May 25, 2011