- 6 - moves for relief from the disputed stipulations because they “include legal conclusions which are erroneous” and “so that the record is consistent and accurate”. On June 5, 2006, petitioners filed a response opposing the motion. Neither party requested a hearing on respondent’s motion, and we are satisfied that a hearing is not necessary to rule on the motion. Discussion The stipulation process is considered “the bedrock of Tax Court practice” and acts “as an aid to the more expeditious trial of cases”. Branerton Corp. v. Commissioner, 61 T.C. 691, 692 (1974). Stipulations eliminate burdensome and unnecessary discovery and result in “an orderly trial with a full and fair exposition of the facts.” Teller v. Commissioner, T.C. Memo. 1992-402. Stipulations narrow controversies to their essential issues of dispute, Estate of Quirk v. Commissioner, 928 F.2d 751, 759 (6th Cir. 1991), affg. in part and remanding in part T.C. Memo. 1988-286, and materially assist a court in managing its caseload, see Stamos v. Commissioner, 87 T.C. 1451, 1456 (1986). Generally, a stipulation of fact is binding on the parties, and the Court is bound to enforce it. Rule 91; Stamos v. Commissioner, supra at 1454. Rule 91(e) provides an exception by permitting relief from the binding effect of a stipulation where justice so requires. Courts generally enforce stipulations unless “manifest injustice” would result. Bokum v. Commissioner,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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