Robert S. Cohen and Margery Cohen - Page 47

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          respondent agreed that the protest letter was equivalent to an              
          executed piggyback agreement.  Petitioners’ counsel essentially             
          argues that by stipulation respondent’s counsel has agreed to               
          concede the issues in dispute in this case.  The language of the            
          stipulation does not support this startling conclusion, nothing             
          else in the record supports it, and respondent’s counsel clearly            
          and explicitly has denied it.  We disagree with petitioners’                
          counsel’s interpretation of the stipulation of facts.                       
               Accordingly, we hold that petitioners are not entitled to              
          the benefits of the Miller settlement or the piggyback agreement            
          concerning Plastics Recycling cases.                                        
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          






















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