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cases were entered before respondent filed answers therein.
Petitioners’ argument is without merit. A stipulated decision
reflects the compromise and settlement of a tax case, which is
governed by general principles of contract law. Robbins Tire &
Rubber Co. v. Commissioner, 52 T.C. 420, 435-436, supplemented by
53 T.C. 275 (1969). The decision in a stipulated case is deemed
rendered on the date the Court enters it. See sec. 7459(c).
Neither the ability of the parties to enter into a stipulated
settlement nor the ability of the Court to enter a decision
reflecting the stipulated settlement depends upon the
Commissioner’s filing an answer.
Petitioners also argue that res judicata is inapplicable
here because this Court lacked jurisdiction in the transferee
liability cases in that the corporation’s notice of deficiency
was invalid. Petitioners argue that the corporation’s notice of
deficiency was invalid because it was based on the taxable year
ending December 31, 1995, whereas the corporation’s final tax
period ended August 31, 1995, just before it was liquidated.
Petitioners are mistaken in their premises as to the
prerequisites of this Court’s jurisdiction in a transferee
liability case. The Tax Court has jurisdiction in a case
commenced by respondent’s issuance to a transferee of a notice of
liability. See sec. 6901; Rule 13(a); Groetzinger v.
Commissioner, 69 T.C. 309 (1977). The validity of a notice of
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