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independently investigate the Sentinel recyclers or see a
Sentinel recycler or any other type of plastic recycler prior to
participating in the recycling ventures.
At the conclusion of the trial in this case, respondent's
counsel stated that there was a "non-plastics issue in this case"
that would be resolved without trial. Counsel requested that the
record remain open for submission of a stipulation of settled
issues, and the Court ordered that the record remain open only
for submission of such stipulation in the "other issue".
The deficiency notice to petitioner for 1982 concerned
petitioner's investment in a partnership designated as Efron
Investors II (Efron II). Efron II invested in a shopping center
and also in Dickinson Recycling Associates, a TEFRA partnership
(a partnership subject to sections 6221 through 6231, the TEFRA
provisions) that was involved in the Plastics Recycling
transactions. Fred Gordon, as counsel for petitioner, and
Timothy Murphy of respondent's Detroit District Counsel's Office
negotiated the resolution of the shopping center issues and each
signed the following proposed stipulation of agreed adjustments
in this case:
THE PARTIES HEREBY STIPULATE the following terms
in settlement of the adjustments in Respondent's Notice
of Deficiency pertaining to the petitioner's interest
in Efron Investors II Partnership for 1982:
1. The respondent in its Notice of Deficiency
disallowed $10,248.00 of petitioner's claimed losses
relative to Efron Investors II Partnership.
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