- 16 - enforce it in all respects. Petitioner states that the record has remained open for receipt of this stipulation. We agree that the record has been held open for receipt of a stipulation relating to nonplastics issues. Respondent has agreed to the first two numbered paragraphs of the proposed stipulation of agreed adjustments. Those paragraphs state: 1. The respondent in its Notice of Deficiency disallowed $10,248.00 of petitioner's claimed losses relative to Efron Investors II Partnership. 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. The parties are in agreement as to the introductory paragraph of the proposed stipulation, as quoted in our findings of fact, and also as to the first two paragraphs, quoted there and above. Accordingly, petitioner's motion is granted insofar as it relates to such paragraphs only, and they are received into the record as stipulated by the parties. Additionally, we note that respondent has conceded that section 6621(c) is inapplicable to the deficiency for 1982. Petitioner urges that we also require that respondent stipulate to a third paragraph of the proposed stipulation of agreed adjustments as follows: 3. As a result of this stipulation, all issues pertaining to Efron Investors II Partnership for 1982 have been resolved.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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