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B. Collateral Estoppel
Petitioners contend that respondent is estopped from
determining a deficiency as to their claimed IRA deduction for
2002 because of a decision document entered by this Court
pursuant to a settlement by the parties that allowed petitioners
an IRA deduction for 2001. Petitioners claimed an IRA deduction
of $2,000 on their Federal income tax return for 2001, a year in
which they had no compensation as that term is used in section
219(b)(1)(B) and (f)(1). However, the Appeals Office resolved
the IRA deduction issue for 2001 in petitioners’ favor by
allowing the deduction because it was substantiated by a third
party. No question was raised as to whether the deduction was
limited by petitioners’ compensation in that year. The IRA
deduction issue for 2001 was resolved by a decision document that
this Court entered on December 6, 2004, in the case of Gary H.
and L. Marianne Bell v. Commissioner, docket No. 2788-04S.
Respondent asserts that the decision document alone, which
was signed by the parties and entered by the Court with respect
to 2001, is not sufficient for invoking collateral estoppel
against respondent to preclude the denial of the IRA deduction
claimed by petitioners for 2002. We agree. The decision
document for the tax year 2001 only effectuated a settlement of
that case. There was no stipulation of facts in support of the
settlement. There was no trial on the merits of the IRA
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