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This was a decision regarding two specific tax years. The decision stated specifically that it was "Pursuant to agreement of the parties in this case". There was no trial, no evidence adduced, no finding of facts by the Tax Court, and no stipulation of facts by the parties. The decision said that the liabilities assessed for these years were "abated", but did not say what the true liabilities for those years were. Does this decision have any res judicata or collateral estoppel effect?