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receipts was actually interest income; the parties seem to read
the stipulation as to the 1982 item the same way. We conclude
that justice does not require us to relieve petitioner from the
effect of the parties’ stipulations. See Rule 91(e), Tax Court
Rules of Practice and Procedure; Louisiana Land & Exploration Co.
v. Commissioner, 90 T.C. 630, 648 (1988).
_____________________________
Time after time petitioner has interposed objections or new
considerations which have had the effect of delaying resolution
of the instant case and only rarely have affected the decision to
be entered. Petitioner stated that the matters dealt with in
this opinion were raised after discussion with an unnamed tax
adviser. Notwithstanding petitioner’s frequent protestations
about his inability to understand the tax laws and our agreement
with him that much of the Internal Revenue Code would challenge
an Einstein, we are satisfied from our observations of petitioner
that he has a reasonably good understanding of the essentials of
those Code provisions that apply to him. Under these
circumstances, if petitioner proceeds in a like manner in a
future case, he should understand that the Court may be inclined
to give serious consideration to imposition of a penalty under
section 6673. Petitioner may not be then able to hide behind the
asserted advice of his unnamed tax adviser.
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