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SENECA LTD. v. COMMISSIONER

Docket No. 37276-87.

92 T.C. 363 (1989)

SENECA, LTD., H. QUINTIN FOSTER, JR., and DOROTHY L. FOSTER, PARTNERS OTHER THAN THE TAX MATTERS PARTNER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 16, 1989.

Attorney(s) appearing for the Case

Paul S. Schleifman, for the petitioners.

R. Alan Lockyear, for the respondent.

OPINION

WILLIAMS, Judge:

This case is before us on respondent's motion to dismiss for lack of jurisdiction on the ground that petitioners failed to file their petition for readjustment of partnership items within the time prescribed by section 6226(b)(1)1 of the partnership audit and litigation procedures. Petitioners object on the ground that the final notice of partnership administrative...

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