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a particular taxable year after this Court had made a determina-
tion with respect to that debtor's tax liability.
We agree with respondent that stipulation 72 and the exhibit
referred to therein are inadmissible under FRE 408. The Advisory
Committee's Note to FRE 408 states in pertinent part: "While the
rule is ordinarily phrased in terms of offers of compromise, it
is apparent that a similar attitude must be taken with respect to
completed compromises when offered against a party thereto." 56
F.R.D. 183, 226 (1973). Stipulation 72 and the exhibit ref-
erenced therein are evidence of a completed compromise. Each
petitioner claims that his liability as a transferee "depends on
Harry Kayian, Jr.'s status as a transferee, and because the
government is now barred from asserting transferee liability
against him, Petitioners can have no liability." Thus, petition-
ers are attempting to use stipulation 72 and the exhibit refer-
enced therein to establish the invalidity of respondent's deter-
minations that petitioners are liable as transferees. We con-
clude that that evidence is inadmissible under FRE 408. Conse-
quently, stipulation 72 and the exhibit referenced in that
stipulation shall be deemed stricken from the record in these
cases.3
3On brief, respondent makes no argument about the admissi-
bility of the testimony of Philip Doyle (Mr. Doyle), the attorney
who represented the United States in Mr. Kayian, Jr.'s bankruptcy
(continued...)
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