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proper investigation before he executed the Stipulation. Under
the circumstances of this case, we believe that justice is best
served by holding the parties to the terms of the Stipulation.
See id.
Respondent also moves for relief from the referenced
stipulations “so that the record is consistent and accurate”.
However, we do not agree that our denial of relief would lead to
an inconsistent or inaccurate result. The only evidence offered
by respondent to demonstrate that the disputed stipulations are
wrong consists of an undated copy of Form 886-Z, Partners’ or S
Corporation Shareholders’ Shares of Income, bearing the name
“Greenwich Associates” and references to taxable years 8212,
8312, and 8412 (48 pages), and a letter dated August 3, 1990,
which appears to be a transmittal letter but which does not refer
to Form 886-Z. The documents are not authenticated, are not
stipulated to by the petitioners, and are not sufficient to
establish that the disputed stipulations are erroneous.
Moreover, respondent does not allege that the documents are newly
discovered or that the documents were not available to him before
the Stipulation was executed and the motion to submit the case
under Rule 122 was filed.
Because the parties agreed in their joint motion, which we
granted, to submit the case under Rule 122, the record in this
case is limited to the pleadings and the Stipulation. At this
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