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Cir. 2000). A settlement is a contract, and general principles
of contract law apply in interpreting the settlement. Id. at 330
(citing Robbins Tire & Rubber Co. v. Commissioner, 52 T.C. 420,
435-436, supplemented by 53 T.C. 275 (1969)). A settlement may
be reflected in a formal written agreement or more informally,
such as in an offer and acceptance made by an exchange of
letters. Id. (citing Lamborn v. Commissioner, T.C. Memo. 1994-
515). Written settlement agreements are enforced as binding
agreements. Id. (citing Haiduk v. Commissioner, T.C. Memo. 1990-
506).
Ordinarily, once a settlement has been reached, it cannot be
repudiated by either party. Id. However, we may relieve a party
of an otherwise binding settlement agreement if the party can
show a lack of formal consent, fraud, mutual mistake, or other
similar ground. Id. at 335; Revell v. Commissioner, T.C. Memo.
2007-37; see also Stamm Intl. Corp. v. Commissioner, 90 T.C. 315,
321-322 (1988).
Both parties signed the stipulation in this case creating an
enforceable, binding settlement agreement between them. Counsel
for respondent notified the Court on the day of trial that a
settlement had been reached between the parties and lodged the
stipulation on behalf of both parties. Based on the parties’
representation that a settlement of all outstanding issues had
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