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concession of some rights as a consideration for those secured
and the settlement stipulation is entitled to all of the sanctity
of any other contract.” Saigh v. Commissioner, 26 T.C. 171, 177
(1956). Absent wrongful misleading conduct or mutual mistake, we
will enforce a stipulation of settled issues in accordance with
our interpretation of its written terms. See Stamm Intl. Corp.
v. Commissioner, 90 T.C. 315, 322 (1988); Korangy v.
Commissioner, T.C. Memo. 1989-2, affd. 893 F.2d 69 (4th Cir.
1990).
The stipulation was entered into fairly and freely by both
parties. The stipulation of settled issues was filed after
petitioner wrote a letter to the Clerk of the Court conceding
respondent’s position that there is no reasonable cause exception
for failing to revoke BP Concessions’ S corporation election. In
that letter, petitioner stated that he wished to discontinue the
case. The stipulation of settled issues was also filed after the
Court held a telephone conference with the parties discussing
this issue. Petitioner has not shown mutual mistake or
misleading conduct or that he was unaware of the consequences of
the stipulation.
In the petition and at trial, petitioners’ only challenge to
the underlying tax liability was that they were entitled to a
reasonable cause exception on account of petitioner’s illness.
On the basis of the stipulation of settled issues, we find that
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