-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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