Lamanna

MEMORANDUM **

Lidia and Frank Lamanna appeal the May 27, 2003 decision of the United States Tax Court in their consolidated cases arising from the Lamannas’ petitions seeking redetermination of tax deficiencies asserted by the Commissioner of Internal Revenue for tax years 1986 to 1991. The Tax Court granted the Commissioner’s motion for entry of decision, enforcing the Stipulation of the Settled Issues signed by all parties. The court determined pursuant to the Stipulation that for the 1986 tax year the Lamannas owe $3,096 plus interest and penalties, but for tax years 1987 to 1991 the Lamannas owe nothing. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a)(1). We affirm in part, vacate in part and remand to correct an undisputed error in calculating the total amount due.

“The tax court’s decision to enforce a stipulation is reviewed for abuse of discretion. A stipulation will generally be enforced unless manifest injustice would result.” Bail Bonds by Marvin Nelson, Inc. v. Comm’r of Internal Revenue, 820 F.2d 1543, 1549 (9th Cir.1987) (internal citation omitted). We review the Tax Court’s legal conclusions de novo, and its findings of fact for clear error. Baizer v. Comm’r…