Graeme C. Revell and Brenda S. Revell - Page 2

          underlying his requested decision.1  Petitioners object to                  
          respondent’s motion, asserting, as we understand it, that the               
          decision to be entered in this case should be based not on the              
          settlement stipulation but on figures computed by respondent                
          during settlement negotiations.  Respondent has filed with the              
          Court a reply to petitioners’ opposition.  For the reasons stated           
          herein, we shall grant respondent’s motion.                                 
               A controversy before this Court may be settled by the                  
          parties through stipulation.  See Dorchester Indus. Inc. v.                 
          Commissioner, 108 T.C. 320, 329 (1997), affd. without published             
          opinion 208 F.3d 205 (3d Cir. 2000).  In that a stipulation is              
          essentially a contract, see Stamos v. Commissioner, 87 T.C. 1451,           
          1455 (1986), general principles of contract law determine whether           
          a settlement has been reached and, if so, whether the stipulation           
          is binding and enforceable, see Dorchester Indus. Inc. v.                   
          Commissioner, supra at 330.  Under such principles, we enforce a            
          stipulation of settlement that has led to the cancellation of the           
          trial, absent a showing of lack of formal consent, fraud, mutual            
          mistake, or some similar ground; a mistake by just one party to a           
          stipulation of settlement is not a sufficient ground to disregard           
          the stipulation.  See Dorchester Indus. Inc. v. Commissioner,               

               1 The parties agree on the decision to be entered in each of           
          the other five referenced cases.                                            

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