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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.
3. As a result of this stipulation, all issues
pertaining to Efron Investors II Partnership for 1982
have been resolved.
The parties agree to this STIPULATION OF AGREED
ADJUSTMENTS.
Although Mr. Murphy signed the document on the space
provided for the representative of the acting Chief Counsel of
respondent, he did not submit the original to the Court but
forwarded it to respondent's counsel in charge of the plastics
recycling issues in this case so they could review and coordinate
the presentation of the case. Respondent's supervising counsel
considered the language of the stipulation document to be subject
to misinterpretation and refused to offer it into evidence at
trial. Instead, respondent's counsel requested that the record
be held open for submission of a stipulation of settled issues at
a later date. Petitioner's counsel made no objection, and this
Court granted the request.
On August 10, 1994, respondent's counsel forwarded to
petitioner's counsel a revised proposed stipulation of settled
issues clarifying that the stipulation resolved all non-TEFRA
issues pertaining to Efron II for 1982 and that the "TEFRA issues
pertaining to Efron Investors II as a tier of Dickinson Recycling
Associates, a TEFRA partnership, will be resolved in a separate
proceeding." Petitioner's counsel never executed the revised
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