On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Bailey v. Commissioner (T.C. Memo. 2021-55). The primary issue presented in Bailey v. Commissioner was whether the petitioners should (or could) be relieved from the stipulation of facts that they voluntarily entered into with the IRS before trial. Background to Bailey v. Commissioner The petitioners’ personal income tax returns (and a related corporate return) were audited for a number of