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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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