Johann Keil and Catherine Keil - Page 13

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          Court granted this request and again confirmed with Sommers that            
          the parties had resolved all issues arising out of the notice of            
          deficiency issued to petitioners.  Respondent at that time also             
          lodged with the Court a signed (by Montgomery and Sommers) copy             
          of the second stipulation of settled issues.  The second                    
          stipulation of settled issues was generally a copy of the first             
          stipulation of settled issues modified to state the terms of the            
          settlement of the five issues which were listed in the first                
          stipulation of settled issues as then still in dispute.  The                
          lodged document stated as to these five issues that (1) for 1993,           
          petitioners could deduct $158,320 of contract labor in excess of            
          the $463,577 referenced in the first stipulation of settled                 
          issues (i.e., a total deduction of $621,897), (2) for 1994,                 
          Continuum (and thus petitioners) could not deduct any business              
          expenses in excess of the $871,480 referenced in the first                  
          stipulation of settled issued, but that Continuum (and thus                 
          petitioners) had to realize additional income of $225,411,                  
          (3) for 1994, petitioners could not under section 1244 deduct any           
          stock loss as to Quest, (4) for 1993, petitioners were liable for           
          the section 6662(a) accuracy-related penalty, and (5) for 1994,             

               4(...continued)                                                        
          merely states the amount of petitioners’ tax liability for the              
          relevant years and makes no mention of any specific issue                   
          underlying that liability.  The parties’ settlement of the issues           
          underlying the settlement stipulation, on the other hand, was set           
          forth in the first stipulation of settled issues and the second             
          stipulation of settled issues.                                              





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