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tax for failure to file a return under section 6651(a)(1) for
1987. On brief, respondent concedes the claimed addition to tax
for failure to pay under section 6651(a)(2) for 1987. At trial,
petitioners conceded the claimed additions to tax for 1988 for
both delinquency under section 6651 and negligence under section
6653. At trial, the parties stipulated that there are no
additions to tax under section 6654. On brief, with respect to
the deficiencies in tax for 1987 and 1988, petitioners propose
that we find that, but for certain claimed credits and refunds
still in issue, there are deficiencies in tax of $9,232 and
$40,329 for those years, respectively. Respondent agrees with
those proposed findings of fact, and we shall treat such
agreements as constituting a stipulation of settlement with
respect to those deficiencies, which we accept. The parties
agree that petitioners have raised as issues in this case
overpayments on account of (1) withholding and refundable credits
for 1989, 1990, and 1991, and (2) net operating loss (NOL)
carrybacks from 1991 and 1992. At trial, petitioners conceded
that there was no timely claim for any overpayment on account of
withholding and refundable credits for 1991. On brief,
respondent concedes that petitioners submitted timely refund
claims for overpayments for 1989 and 1990 (except with respect to
NOL carrybacks), and states that the necessary computations to
satisfy those claims can be made under Rule 155. We accept the
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