Memorandum Opinion
NIMS, Judge:
Petitioners and respondent filed an executed stipulation of settled issues (stipulation) regarding the Newcomb Government Securities Tax Shelter (Newcomb). Subsequently, respondent filed a Motion for Entry of Decision based on the stipulation, in response to which petitioners filed their "Memorandum of Law" (Memorandum) in opposition to respondent's Motion. In the Memorandum petitioners seek to be relieved of the binding effect...
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