Joseph P. McGivney, Jr. - Page 2

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            documents and shares them with respondent.  We hold that we shall                          
            not.  Section references are to the Internal Revenue Code for the                          
            year in issue.                                                                             
                  Respondent determined a $59,114 deficiency in petitioner's                           
            1995 Federal income tax and additions thereto of $2,662.95 and                             
            $3,205.33 under sections 6651(a)(1) and 6654, respectively.                                
            While residing in Illinois petitioner petitioned the Court to                              
            redetermine these amounts.  The Court set this case for trial in                           
            Chicago, Illinois, on March 20, 2000.  On the date set for trial                           
            the parties filed the stipulation, and the Court ordered that the                          
            stipulated decision document be submitted to the Court by April                            
            19, 2000.  Petitioner now refuses to sign the decision document,                           
            asserting that he has recently become aware that documents may                             
            exist which support the allegations set out in his petition.                               
            Petitioner asserts:                                                                        
                  petitioner believes that the financial records and                                   
                  information [alleged to be newly discovered but not in                               
                  petitioner’s possession] will indicate that the taxable                              
                  income amounts, related tax liability, and interest and                              
                  penalty previously conceded in the stipulation of                                    
                  settled issues, are inaccurate and petitioner is harmed                              
                  by conceding to such amounts.                                                        
            Petitioner does not move the Court to vacate the stipulation1 but                          

                  1Even assuming arguendo, that petitioner is making such a                            
            motion through his response to respondent's motion for entry of                            
            decision, we would deny the motion under the rationale of Stamm                            
            Intl. Corp. v. Commissioner, 90 T.C. 315, 321 (1988)                                       

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