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TEMPEST ASSOCIATES v. COMMISSIONER

Docket Nos. 13298-88, 9795-89.

94 T.C. 794 (1990)

TEMPEST ASSOCIATES, LTD., FUTURE INVESTORS, I, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT TEMPEST ASSOCIATES, LTD., BENJAMIN A. VASSALLO, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 4, 1990.

Attorney(s) appearing for the Case

Leslie S. Klinger and Abraham Gutwin, for the petitioners.

Cheryl B. Harris and Henry S. Schneiderman, for the respondent.

OPINION

RUWE, Judge:

These cases were assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(4) and Rule 180 et seq.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

POWELL, Special Trial Judge:

These cases have been consolidated by the...

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