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late date, we shall not consider documents outside those
submitted with the pleadings or Stipulation. The disputed
stipulations are consistent with each other and with the rest of
the evidentiary record. The parties entered into the disputed
stipulations on their own accord; there is no evidence of any
fraud or duress.
Respondent claims that he mistakenly agreed to the disputed
stipulations. If respondent erred, however, his mistake was
unilateral. Responsibility rested with respondent’s counsel to
understand the significance of the disputed stipulations and to
examine his case thoroughly before agreeing to the disputed
stipulations. See Korangy v. Commissioner, supra. We perceive
no injustice in holding the parties to the terms of the
Stipulation.
For the reasons described, we shall deny respondent’s Motion
for Relief from Stipulations.
An appropriate order
will be issued.
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Last modified: May 25, 2011