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AMERICAN EDUCARE, LTD. v. COMMISSIONER

Docket Nos. 34128-87, 38384-87, 7081-88, 22864-88.

59 T.C.M. 212 (1990)

T.C. Memo. 1990-159

American Educare, Ltd., Patrick Moretti, Tax Matters Partner, et al. v. Commissioner.

United States Tax Court.

Filed March 26, 1990.

Attorney(s) appearing for the Case

Allan P. Harris, 2635 Century Pkwy., Atlanta, Ga., and Leon A. Van Geldern, for the petitioners. Carolyn Lee Harber and Thomas R. Thomas, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, within the time allowed by written consents extending the periods of limitations, issued notices disallowing claimed deductions and credits of petitioner-partnership and of the other petitioners in these consolidated cases.2 The issues are whether petitioners have proved that their consents to extend the periods of limitations are invalid because the consents...

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