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Barrister and a limited partnership that also was a party in
Anderson Equip. Associates v. Commissioner, supra.
Our opinion in Chimblo v. Commissioner, supra, was filed in
December of 1997. Therein, we sustained respondent’s imposition
of sections 6653(a)(1), (a)(2), and 6661 additions to tax.
On March 16, 1998, in the instant case, petitioners and
respondent entered into a settlement stipulation, referred to by
the parties as a piggyback agreement, which provided that all of
the issues in the instant case would be resolved on the same
basis as those issues are finally resolved in Chimblo v.
Commissioner, supra. The stipulation specifically stated as
follows:
All of the remaining issues in this case
shall be resolved on the same basis and by
application of the same formula as that which
resolves the like issues in the case in this
Court of Catherine Chimblo and Estate of Gus
Chimblo, Deceased, Catherine Chimblo,
Executrix, Docket No. 16546-96 (hereafter the
CONTROLLING CASE), as if Petitioners in this
case were the same as the taxpayers in the
CONTROLLING CASE. If an issue in the
CONTROLLING CASE is appealed, the final
decision, whether on appeal or on remand,
shall be binding on the like issue in this
case.
In a number of motions for continuance of scheduled trial
dates (filed subsequently to the above March 16, 1998, settlement
stipulation), the parties herein represented to the Court that
all of the disputed issues in this case would be resolved on the
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