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             
          issues.                                                                     
               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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