"The trial court may disregard stipulations between parties only if accepting them would be manifestly unjust or if the evidence contrary to the stipulation was substantial." Hymel v. Commissioner, 794 F.2d 939, 940 (5th Cir. 1986) ( per curiam) (internal quotation marks omitted). There is some evidence in the record that contradicts the stipulated date.

This court has said that a "trial court may disregard stipulations between parties only if accepting them would be manifestly unjust or if the evidence contrary to the stipulation was substantial." United States v. Ret. Serv. Group, 302 F.3d 425, 430 (5th Cir. 2002) (quoting Hymel v. Comm'r, 794 F.2d 939, 940 (5th Cir. 1986). Here, accepting the stipulation between Okoye and the government would not be manifestly unjust, and there is not substantial evidence contrary to the stipulation.

We uphold the court's ruling on this point. Hymel v. Commissioner, 794 F.2d 939, 940 (5th Cir. 1986). Like the remedial stage of this suit, Hymel was tried largely on the basis of stipulated facts.

There must be a direct impact between membership and the business. Hymel v. Comm'r, 794 F.2d 939 (5th Cir 1986). Thus, for example, it is not sufficient that a taxpayer show he obtained more business in general by being a member of a country club, as that does not show the expense was primarily for a business purpose.