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and the Sentinel EPE recyclers considered in this case, are the
same transaction and machines considered in Provizer.
Issue 1. Resolution of Questions Concerning Petitioner's
Investment in Efron Investors II for 1982.
In the notice of deficiency, respondent determined a
deficiency in petitioner's 1982 Federal income tax in the amount
of $4,502. The deficiency for 1982 resulted from respondent's
examination results with respect to the 1982 partnership return
of Efron II and the consequent adjustment of petitioner's claimed
deductions from Efron II in the amount of $10,248.
Prior to trial, the parties undertook to reach an agreement
as to a portion of the Efron II investment concerning a shopping
center. Respondent's attorney in charge of that issue prepared a
proposed stipulation of agreed adjustments; petitioner's counsel
signed it; the attorney who prepared the document also signed it
and forwarded it to counsel for respondent in charge of the
plastics recycling issues for review and coordination. That
counsel for respondent disapproved a portion of the proposed
stipulation as subject to misinterpretation and the original of
the proposed stipulation never was delivered to petitioner's
counsel or submitted to this Court.
Petitioner has filed a motion, which the Court has
designated as petitioner's motion to reopen record, in which
petitioner urges that respondent be required to produce the
proposed stipulation of agreed adjustments and that the Court
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