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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,
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