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amounts reflected in the notice of deficiency. Respondent also
concedes that the initial cost of goods sold that was disallowed
in the notice of deficiency for 1995 should be reduced from
$260,282 to $47,884. Respondent also concedes that petitioners
are entitled to additional Schedule C expense deductions (in
excess of what was initially reported by petitioners) in the
amounts of $109,436, $104,690, and $12,155 for 1993, 1994, and
1995, respectively.
OPINION
Stipulation of Facts
In the stipulation of facts, petitioners conceded unreported
gross receipts for each of the years in issue. In their brief,
however, petitioners claim that they did not stipulate to these
amounts and that respondent’s counsel told them they had to sign
the stipulation prior to trial. Petitioners have not moved to be
relieved from the stipulation or presented grounds that they
should not be bound to their admissions. See Rule 91(e). We are
not persuaded by petitioners’ argument and hold that the
stipulation remains binding.
Cost of Goods Sold
Petitioners continue to dispute that respondent incorrectly
disallowed $47,884 of petitioners’ claimed cost of goods sold for
1995. Respondent argues that petitioners have failed to
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