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proposed stipulation of settled issues in this case although they
did execute such a revision at about the same time in another
case involving substantially similar circumstances. See Reister
v. Commissioner, T.C. Memo. 1995-305.
Dickinson Recycling Associates, Sam Winer, Tax Matters
Partner v. Commissioner, docket No. 13191-89 (Dickinson), was
calendared for trial at a special session of the Court in March
1994, in Detroit, Michigan, the same session at which the instant
case was tried. The Dickinson partnership is a partnership
subject to the TEFRA provisions at sections 6221 through 6231.
Efron II, a limited partnership formed in June 1982, invested in
a limited partnership interest in Dickinson, and consequently, is
a second tier investor in a plastics recycling transaction. The
Dickinson case was resolved without trial, and this Court's
decision was entered on February 23, 1994, and became final on
May 24, 1994.
On June 9, 1995, petitioner filed a document which the Court
has designated as petitioner's motion to reopen record. In such
motion, petitioner urges that the Court require respondent to
produce the proposed stipulation of agreed adjustments which
petitioner contends both parties executed prior to trial and that
we bind respondent to petitioner's interpretation of that
document not only as to the shopping center issues, but also as
to all other issues, including the treatment of petitioner's
interest in Dickinson through Efron II.
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