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Petitioner interprets this paragraph as prohibiting any
adjustments to petitioner's tax for 1982 as a result of any
interest in a TEFRA partnership, specifically the Efron II
partnership interest in Dickinson. Petitioner contends that the
attorney who drafted and signed the proposed stipulation for
respondent was authorized to represent respondent and that
respondent's failure to produce the document is impermissible.
Respondent's position is that this Court has no jurisdiction to
decide a TEFRA partnership issue at the partner level, that the
Detroit docket attorney had no authority to execute a stipulation
with respect to the plastics recycling issue in this case, and
that the paragraph in question, properly interpreted, relates
only to the shopping center or nonplastics issues in this case.
Respondent has filed a motion to dismiss for lack of jurisdiction
and to strike the portions of the pleadings relating to
Dickinson. Respondent urges that we deny petitioner's motion to
reopen the record and grant respondent's motion to dismiss and to
strike. We agree with respondent except as to the agreement of
the parties with respect to the shopping center adjustments and
respondent's concession as to section 6621(c) for 1982.
During 1982, Efron II invested in Dickinson Recycling
Associates, a partnership that is subject to the provisions of
sections 6221 through 6231 (the TEFRA provisions) enacted by the
Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248,
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