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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.
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