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from an activity entitled "Computer Books + Tapes" claimed on
Schedule C of their 1980 and 1981 returns.
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by reference, and
they are found accordingly. Petitioners resided in Briarcliff
Manor, New York, at the time they filed their petitions.
1. Whether All Issues Have Been "Resolved" and "Settled"
Preliminarily, we address petitioners' contention that they
have "settled" and "resolved" all issues in the instant case.
Petitioners argue that they previously reached agreement with
respondent concerning all issues in the instant case and that
they previously submitted checks to respondent in full
satisfaction of all taxes and interest owed for the years in
issue. Petitioners point to certain payments they allege to have
been made to the Internal Revenue Service which, petitioners
allege, "totally resolved" all issues in the instant case.
Respondent argues that although petitioners may have made
payments, such payments were applied to taxable years other than
those at issue in the instant case, and, in any event, that
payments made by petitioners after the notice of deficiency is
mailed do not affect our jurisdiction to decide the correctness
of the asserted deficiencies and income tax overpayments.
We agree with respondent. Petitioners misunderstand the
purpose of the instant proceedings. Respondent determined
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