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FRAZEE McCALL JOINT VENTURE v. COMMISSIONER

Docket No. 11297-88.

60 T.C.M. 1466 (1990)

T.C. Memo. 1990-639

Frazee McCall Joint Venture, JNO. McCall Coal Co., Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed December 19, 1990.

Attorney(s) appearing for the Case

John S. McDaniel, Jr., and Robert K. Briskin, One North Charles St., Baltimore, Md., for the petitioner. Elizabeth S. Henn, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

This is a proceeding pursuant to section 6226 for a readjustment of partnership items of Frazee-McCall Joint Venture (petitioner), for the taxable years ending December 31, 1983, 1984, and 1985.

Petitioner was formed and controlled by a 50-percent partner, the Jno. McCall Coal Co., and two related 25-percent partners, Edward and Donald Frazee.

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