Graeme C. Revell and Brenda S. Revell - Page 3

          supra; Stamm Intl. Corp. v. Commissioner, 90 T.C. 315, 320-321              
               Petitioners claim that the Court should disregard the                  
          settlement stipulation signed by them because the decision                  
          flowing from the stipulation does not reflect their understanding           
          of the settlement.  We disagree that we should disregard the                
          settlement stipulation for the reason that petitioners state.               
          Even if petitioners had mistakenly signed the document, such a              
          unilateral mistake is not a sufficient ground to set aside an               
          otherwise enforceable settlement stipulation.  Such is especially           
          so given that petitioners are represented by counsel and that               
          their signing of the settlement stipulation was on the eve of               
          their trial.  See Stamm Intl. Corp. v. Commissioner, supra at               
               We hold that petitioners are bound by the amounts shown in             
          the settlement stipulation and the decision that flows therefrom.           
          We have considered all arguments made by petitioners for a                  
          contrary holding and consider those arguments not discussed                 
          herein to be without merit.  To reflect the foregoing,                      

                                                  An appropriate order and            
                                             decision will be entered.                

Page:  Previous  1  2  3  

Last modified: May 25, 2011