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On July 11, 1995, respondent filed respondent's response to
petitioner's motion to reopen record in which respondent argues
that this Court has no jurisdiction over TEFRA partnership items
in this case and, in any event, respondent did not enter into the
settlement sought by petitioner.
On July 17, 1995, respondent filed a motion to dismiss for
lack of jurisdiction and to strike the claims relating to the
deficiency attributable to partnership items. Petitioner filed
petitioner's response to respondent's motion on July 18, 1995,
and attached affidavits by petitioner's counsel Lois C. Blaesing
and petitioner's former counsel Fred Gordon. Petitioner
submitted such response pursuant to Rule 50(c) in lieu of
attending the hearing on the pending motions and specifically
addressed respondent's motion to dismiss in such response. On
July 19, 1995, at Washington, D.C., pursuant to notice, the Court
conducted a hearing with respect to the pending motions at which
respondent proved that respondent's docket attorney in Detroit,
Michigan, Timothy Murphy, had no authority to settle a plastics
recycling issue but only was authorized to settle the shopping
center issue for 1982 in this case. At such hearing,
respondent's counsel conceded the 1982 shopping center issue, and
also the issue as to section 6621(c) consistently with the first
two paragraphs (and only those paragraphs) of the proposed
stipulation of agreed adjustments, as quoted above.
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