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OPINION
Respondent contends that the May 27, 1996, assessment was
taken into account in determining the deficiency stipulated by
the parties. Petitioners, however, contend that the assessment
is invalid, pursuant to section 6213(a), and that their liability
is limited to the $2,931 set forth in the Court’s March 13, 1997,
decision.
The petition clearly reflects petitioners’ decision to
contest the entire deficiency determined by respondent. Thus,
the Court had jurisdiction to determine petitioners’ correct tax
liability relating to 1993. See Naftel v. Commissioner, 85 T.C.
527, 533 (1985). On March 13, 1997, the parties signed a
settlement agreement, pursuant to which a decision was entered by
the Court. This decision is final and binding on the parties
pursuant to the terms of their stipulation. Accordingly,
respondent may collect only $2,931, the amount set forth in the
Court’s March 13, 1997, decision.
Contentions we have not addressed are irrelevant, moot, or
meritless.
Decision will be entered
for petitioners.
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Last modified: May 25, 2011