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POINT COMFORT VENTURE v. COMMISSIONER

Docket No. 2099-89.

60 T.C.M. 1193 (1990)

T.C. Memo. 1990-574

Point Comfort Venture, F & E Erection Company, Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed October 31, 1990.

Attorney(s) appearing for the Case

W. Thomas Weir, 300 Convent St., San Antonio, Tex., and Edward S. Koppman, 1700 Pacific Ave., Dallas, Tex., for the petitioner. Phillip A. Pillar, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

By notice of Final Partnership Administrative Adjustment (FPAA), respondent made the following adjustments in petitioner's Federal income tax:

Year                           Adjustment

1983 ......................   $4,277,477.38
1984 ......................    2,807,344.46
1985 ......................    1,535,624.62

The sole issue for decision is whether Point...

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