Robert H. Avellini - Page 11

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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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