Robert H. Avellini - Page 16

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            enforce it in all respects.  Petitioner states that the record                              
            has remained open for receipt of this stipulation.  We agree that                           
            the record has been held open for receipt of a stipulation                                  
            relating to nonplastics issues.  Respondent has agreed to the                               
            first two numbered paragraphs of the proposed stipulation of                                
            agreed adjustments.  Those paragraphs state:                                                
                        1.  The respondent in its Notice of Deficiency                                  
                  disallowed $10,248.00 of petitioner's claimed losses                                  
                  relative to Efron Investors II Partnership.                                           
                        2.  The petitioner is allowed to deduct $2,166.00                               
                  of the amount disallowed by the respondent.  The                                      
                  petitioner concedes the remaining amount disallowed of                                
                  $8,082.00.                                                                            
                  The parties are in agreement as to the introductory                                   
            paragraph of the proposed stipulation, as quoted in our findings                            
            of fact, and also as to the first two paragraphs, quoted there                              
            and above.  Accordingly, petitioner's motion is granted insofar                             
            as it relates to such paragraphs only, and they are received into                           
            the record as stipulated by the parties.  Additionally, we note                             
            that respondent has conceded that section 6621(c) is inapplicable                           
            to the deficiency for 1982.                                                                 
                  Petitioner urges that we also require that respondent                                 
            stipulate to a third paragraph of the proposed stipulation of                               
            agreed adjustments as follows:                                                              
                        3.  As a result of this stipulation, all issues                                 
                  pertaining to Efron Investors II Partnership for 1982                                 
                  have been resolved.                                                                   







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