Whether stipulations filed under Tax Court Rule 91(a) & (e) are binding on the parties and the Tax Court

QUESTIONS PRESENTED 1) Whether stipulations filed under Tax Court Rule 91(a) & (e) are binding on the parties and the Tax Court. 2) Whether statements in a court order in one case may be used for their truth in a different case over a hearsay objection. 3) Whether litigation sanctions ordered by a district court and paid to an opposing party are “fines” or “penalties” “paid to a government” under Internal Revenue Code § 162(f) (2006), in light of the change to the code section enacted in the Tax Cuts & Jobs Act of 2017.