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WIND ENERGY ASSOCIATES v. COMMISSIONER

Docket No. 12143-89.

94 T.C. 787 (1990)

WIND ENERGY TECHNOLOGY ASSOCIATES III, WILLIAM C. WARBURTON, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 30, 1990.

Attorney(s) appearing for the Case

Gary P. Kaplan, for the petitioner.

William A. Heard III and Thomas F. Eagan, for the respondent.

OPINION

NIMS, Chief Judge:

This case is before the Court on petitioner's motion for summary judgment and respondent's cross-motion for partial summary judgment. The issue is whether respondent's failure to satisfy the 120-day requirement in section 6223(d) rendered a notice of final partnership administrative adjustment (FPAA) invalid. (All section references are to the Internal Revenue Code of 1954 as amended...

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