Walter S. and Sally H. Newbern - Page 1

                                 T.C. Memo. 1999-112                                  

                               UNITED STATES TAX COURT                                

                   WALTER S. AND SALLY H. NEWBERN, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos.  3792-87, 12619-90.         Filed April 2, 1999.           

               A. Eugene Lewis, for petitioners.                                      
               Judith C. Winkler, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               COLVIN, Judge:  These cases are before the Court on                    
          petitioners’ second motion to set aside stipulations of settled             
               Petitioners contend that their counsel at that time                    
          (petitioners' former counsel) signed stipulations of settled                
          issues in these cases without their authority.  The sole issue              

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