- 67 - Interlake Corp. v. Commissioner, supra, and which petitioner through its old counsel had waived in entering into the stipulation of settled issues that respondent asks us to enforce by entering a decision thereon. Petitioner’s strategy appeared to succeed when the bankruptcy court opined that the 1985 tentative refund was uncollectible by summary assessment because it was a nonrebate refund. Petitioner then tried to get even more mileage out of its nonrebate argument with respect to the 1981 and 1984 tentative refunds in this Court. However, petitioner had to phrase its argument as a jurisdictional challenge, because it had agreed in the stipulation of settled issues to repay the tentative refunds. We have rejected that challenge and shall enforce the stipulation of settled issues in accordance with its terms. In light of the foregoing, Respondent’s motion for entry of decision will be granted, and decision will be entered in accordance with the stipulation of settled issues.Page: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67
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