Olsen

MEMORANDUM

Michael R. and Sheila Olsen (“Olsens”) appeal pro se the Tax Court’s order granting the Internal Revenue Service’s (“IRS”) motion for entry of judgment based upon the parties’ settlement agreement in the Olsens’ action for redetermination of a tax deficiency in 1995. We have jurisdiction pursuant to I.R.C. § 7482(a)(1). We affirm.

The Tax Court’s enforcement of a stipulation is reviewed for an abuse of discretion. See Bail Bonds by Marvin Nelson, Inc. v. Commissioner, 820 F.2d 1543, 1547 (9th Cir.1987). A stipulation is treated as a conclusive admission by the parties to the stipulation unless otherwise permitted by the court or agreed upon by those parties. See Tax Ct. R. 91(e). The Tax Court will not permit a party to a stipulation to qualify, change, or contradict a stipulation in whole or in part, unless manifest injustice will result. See Bail Bonds, 820 F.2d at 1546 .

Here, the Olsens negotiated the terms of, and stated that they agreed to, the stipulations that were read into the Tax Court’s record. In addition, the Olsens presented insufficient evidence that their consent was procured by fraud, coercion, or any misconduct by the government. Moreover, the…