- 11 - 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 revisedPage: 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