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any evidence otherwise discoverable merely because it
is presented in the course of compromise negotiations.
This rule also does not require exclusion when the
evidence is offered for another purpose, such as prov-
ing bias or prejudice of a witness, negativing a con-
tention of undue delay, or proving an effort to ob-
struct a criminal investigation or prosecution.
Respondent argues that the bankruptcy stipulation is ev-
idence of a compromise by the United States in Mr. Kayian, Jr.'s
bankruptcy proceeding, which petitioners in the instant cases
want to use to establish that respondent's determinations against
them are not valid. Consequently, according to respondent, that
evidence is inadmissible under FRE 408.
Petitioners argue that FRE 408 "does not apply to final
judgments in judicial proceedings" and that "because stipulations
entered in prior court proceedings have the preclusive effect of
final judgments, they are admissible in subsequent proceedings to
prove liability for, or invalidity of, the claim that is the
subject of the stipulation." In support of their position,
petitioners rely on In re Cluck, 165 Bankr. 1005 (W.D. Tex.
1993), affd. without published opinion 20 F.3d 1170 (5th Cir.
1994), and In re Camp, 170 Bankr. 610 (Bankr. N.D. Ohio 1994).
We find In re Cluck, supra, and In re Camp, supra, on which
petitioners rely to be distinguishable from the instant cases and
their reliance on them to be misplaced. Moreover, in each of
those cases, 11 U.S.C. sec. 505(a)(2)(A) (1994), prevented the
Bankruptcy Court from relitigating the debtor's tax liability for
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