- 17 - Petitioner interprets this paragraph as prohibiting any adjustments to petitioner's tax for 1982 as a result of any interest in a TEFRA partnership, specifically the Efron II partnership interest in Dickinson. Petitioner contends that the attorney who drafted and signed the proposed stipulation for respondent was authorized to represent respondent and that respondent's failure to produce the document is impermissible. Respondent's position is that this Court has no jurisdiction to decide a TEFRA partnership issue at the partner level, that the Detroit docket attorney had no authority to execute a stipulation with respect to the plastics recycling issue in this case, and that the paragraph in question, properly interpreted, relates only to the shopping center or nonplastics issues in this case. Respondent has filed a motion to dismiss for lack of jurisdiction and to strike the portions of the pleadings relating to Dickinson. Respondent urges that we deny petitioner's motion to reopen the record and grant respondent's motion to dismiss and to strike. We agree with respondent except as to the agreement of the parties with respect to the shopping center adjustments and respondent's concession as to section 6621(c) for 1982. During 1982, Efron II invested in Dickinson Recycling Associates, a partnership that is subject to the provisions of sections 6221 through 6231 (the TEFRA provisions) enacted by the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248,Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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