Memorandum Opinion
WILLIAMS, Judge:
These consolidated cases are before us on the parties' cross motions to dismiss for lack of jurisdiction. The Commissioner determined adjustments to the partnership returns of September Partners, Ltd. ("SPL"), October Partners, Ltd. ("OPL"), and Winter Park Partners, Ltd. ("WPPL") (collectively, "the Partnerships"), for their 1983 taxable years as set forth in his notices of final partnership administrative adjustment...
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