Please help me with creating a tax memo with the following information. Specifically help with the facts that are pertinent to this memo and specific references in the analysis section from RIA checkpoint and IRC.

"Background

Petitioner MacDonald is the sole shareholder of MacDonald's Burgers Company, Inc. (MBC), an S corporation. He filed a late individual income tax return for 2010 on which he did not report on Schedule E, Supplemental Income and Loss, any flow-through income or loss from MBC. His return included a Schedule C, Profit or Loss From Business (Sole Proprietorship), on which he reported gross receipts of $59,491 and total expenses of $102,925. He thus reported on Schedule C a loss of $43,434.1 The IRS examined MBC's return and petitioner's individual return and proposed a number of adjustments. It determined that petitioner received unreported wages of $5,571 during 2010 and that he did not have a distinct Schedule C business. Rather, the IRS determined that the gross receipts and expenses reported on petitioner's Schedule C were in fact attributable to his activities on behalf of MBC. The IRS accordingly zeroed out his Schedule C activity, eliminating Schedule C gross receipts of $59,491 and disallowing Schedule C deductions of $102,925, and folded these items into his Schedule E business. After making the latter adjustments, the IRS determined that petitioner MacDonald had unreported Schedule E flow-through income of $290,703 from MBC. On May 5, 2014, the IRS sent Taxpayer a timely notice of deficiency for 2010. This notice determined an income tax deficiency of $98,761, an addition to tax of $9,440 under section 6651(a)(1) for failure to file timely his 2010 return, and an accuracy-related penalty of $18,224 under section 6662(a). While residing in California, petitioner timely sought redetermination of the deficiency in the California Tax Court. The case was calendared for trial in Los Angeles, California, on April 20, 2015. Prior to the trial date, the parties reached a basis of settlement. On April 10, 2015, the parties filed with the Court a stipulation of settled issues that was signed by petitioner and by counsel for respondent. This stipulation stated that it "resolves all the issues before the Court" and expressed the parties' understanding that "this stipulation of settled issues will be given full effect by the Court when it enters its Decision in this case." The stipulation of settled issues involved mutual concessions. Petitioner agreed that he had unreported wage income of $5,571; that he had no distinct Schedule C business; that the income and expense items reported on his Schedule C should be transferred to his Schedule E business, thus eliminating the reported Schedule C loss of $43,434; and that he was liable for an accuracy-related penalty. Respondent conceded that petitioner had Schedule E flow-through income from MBC of only $84,626 (as opposed to $290,703 as determined in the notice of deficiency) and conceded that petitioner was not liable for any addition to tax under section 6651(a)(1). At the calendar call there was no appearance by or on behalf of petitioner. Counsel for respondent appeared, explained that it would take some time to obtain tax computations, and requested 60 days to file signed decision documents. The Court ordered that executed decision documents be submitted by June 19, 2015. On June 16, 2015, respondent filed a motion for entry of decision. Respondent's counsel represented that he had obtained tax computations consistent with the parties' agreement as set forth in the stipulation of settled issues; that he had prepared a decision document reflecting these tax computations; and that he had - 5 - [*5] sent the computations and draft decision document to petitioner for review. Petitioner, who was being assisted by an accountant not admitted to practice before this Court, disagreed with the computations and declined to sign the decision document. On June 17, 2015, the Court ordered the Taxpayer to file a response to the IRS's motion for entry of decision. Te Court informed MacDonald that if he "disagrees with the tax computations attached to the IRS's Motion then he shall specify, in detail, each item that he believes to be incorrect and shall provide the Court with what he believes to be the correct tax computations." Macdonald responded on July 21, contending that IRS's computations were erroneous because $50,141 of income was being counted twice. In a subsequent filing, which was accompanied by a declaration from his accountant, MacDonald explained that the $50,141 of alleged "duplicate income" represents the sum of $43,434 and $6,707. The first number represents the net "Schedule C Adjustments" shown on line 7 of respondent's Form 5278, Statement of Income Tax Changes: gross receipts of $59,491 minus claimed deductions of $102,925 = ($43,434). This number adds back to petitioner's income the loss originally reported on his Schedule C, consistently with the parties' agreement that all Schedule C items of income and expense should have been reported instead on Schedule E. The second number, $6,707, appears on line 9 of respondent's Form 5278 as the taxable income shown on petitioner's 2010 return as filed.

Issue(s): Was there a valid "meeting of the minds" with respect to the Stipulation of Settled Issues and If not, what is the correct assessment?"