Robert John Kayian, Transferee - Page 26

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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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