Joseph P. McGivney, Jr. - Page 1

                                       T.C. Memo. 2000-224                                             

                                     UNITED STATES TAX COURT                                           

                            JOSEPH P. MCGIVNEY, JR., Petitioner v.                                     
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 10329-99.                  Filed July 28, 2000.                           

                  Thomas J. Handler, for petitioner.                                                   
                  Patricia Pierce Davis, for respondent.                                               

                                        MEMORANDUM OPINION                                             

                  LARO, Judge:  Respondent moves the Court to enter a decision                         
            in accordance with the parties' stipulation of settled issues                              
            (stipulation) filed on March 20, 2000.  Petitioner objects                                 
            thereto, asserting that he has recently learned of possible                                
            evidence of documents which will disprove certain terms of the                             
            stipulation.  We must decide whether, as requested, we shall                               
            defer entry of decision until after petitioner obtains the                                 

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