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them. See Mishawaka Properties Co. v. Commissioner, 100 T.C.
353, 366 (1993) (implied ratification); Kraasch v. Commissioner,
supra at 627-628 (taxpayers were bound by a petition filed and
signed in their names; we deemed their conduct after the petition
was filed to be implied ratification since they knew about the
petition and did not disaffirm it); Gaviola v. Commissioner, T.C.
Memo. 1986-349 (Court rejected taxpayer's attempt to withdraw a
stipulation of settlement based on her claim that her attorney
was without authority to represent her because, even if she did
not initially authorize him to represent her, she ratified his
representation during the course of proceedings before the Tax
Court), affd. without published opinion 819 F.2d 1129 (2d Cir.
1987).
For the reasons stated above, we deny petitioners' second
motion to set aside the stipulations of settled issues.
Petitioners are bound by their settlements of the Elektra
Hemisphere partnership issues.
An order will be issued
denying petitioners' second
motion to set aside stipulations
of settled issues.
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