-417- address this adjustment at this time, inasmuch as the parties have agreed that this issue is part of the ‘Energy Management’ project which is under the jurisdiction of Judge Halpern.” The parties’ stipulation of settlement, however, does not address item 1h from the notice of deficiency. OPINION Respondent’s amendment to answer, filed June 13, 1994, identified the $4,953 adjustment as “Partnership Income/Loss (Fuel Boss - Energy Management Systems)”. Under the circumstances, it appears this issue pertains to the Energy Management Project and the adjustment was overlooked when the parties submitted to the Court their stipulation of settlement for 1978. Consequently, the parties shall make adjustments for this issue in their computations for entry of decision under Rule 155. Issue XV. Whether the Kanters Are Entitled to a Loss From GLS Associates for 1981 (STJ report at 163-165)160 On their 1981 income tax return, the Kanters claimed a $4,283 loss from GLS Associates, a partnership, which respondent disallowed in the notice of deficiency. 160 The Court’s disposition of this issue represents in large measure a wholesale adoption of the recommended findings of fact and conclusions of law set forth in the STJ report. Petitioners have not registered any specific objections to the STJ report regarding this issue.Page: Previous 407 408 409 410 411 412 413 414 415 416 417 418 419 420 421 422 423 424 425 426 Next
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