- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011