Memorandum Findings of Fact and Opinion
STERRETT, Chief Judge:
This consolidated case includes 16 different petitioners. Appendix A sets forth petitioners by name and docket number, the tax years involved, the deficiencies for each year, where the respective returns were filed, and the places of residence for each petitioner when each petition was filed. Each petition involves the tax consequences of petitioners-limited partners' investment in a District...
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