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SUMMERLAND PARTNERSHIP v. COMMISSIONER

Docket No. 3534-88.

56 T.C.M. 759 (1988)

T.C. Memo. 1988-548

Summerland Partnership, Lahad Entendido, Sunburst, Sunshine, Sunland, Summersun, Sumsun, Sunclean, Elmer C. Pratt, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed November 30, 1988.

Attorney(s) appearing for the Case

Elmer C. Pratt, pro se. Steven J. Sibley, for the respondent.

Memorandum Opinion

SWIFT, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent's motion concerns the partnership audit and litigation provisions of sections 6221 through 6233.1 On November 16, 1987, respondent issued notices of final partnership administrative adjustments (FPAAs) with respect to the 1984 tax year of the following partnerships:

 Partnership...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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