Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 359

                                                -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.                                                            





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