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which NOL's do not relate to the Arbitrage Management
adjustments.
The stipulation does not provide that petitioners would be
allowed any NOL deductions carried back from later years
unrelated to the Arbitrage Management adjustments.
With regard to increased interest under section 6621(c), the
stipulation also states that such interest shall apply to
adjustments relating to the “purchase and sale of U.S. Treasury
bills and options for the 1979 tax year” (i.e., to the
adjustments relating to Arbitrage Management). Contrary to
petitioners’ contention, the stipulation does not provide for
such increased interest to be applied to only 50 percent of the
1979 income tax deficiency relating to the Arbitrage Management
adjustments.
Generally, taxpayers and respondent are held to their
written stipulations regarding the manner by which disputed tax
adjustments are to be settled. Stamm Intl. Corp. v.
Commissioner, 90 T.C. 315, 320-322 (1988). Petitioners have not
established any justifiable basis for being relieved from the
stipulation regarding the adjustments relating to Arbitrage
Management.
Further, new issues generally are not to be raised in the
process of making Rule 155 computations. Harris v. Commissioner,
99 T.C. 121, 124 (1992), affd. 16 F.3d 75 (5th Cir. 1994).
Clearly, in the context of the instant Rule 155 computations, the
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