OPINION
NIMS, Chief Judge:
This matter is before the Court on petitioners' motion to reconsider granting of respondent's motion to dismiss for lack of jurisdiction and to strike with respect to section 6621(c), I.R.C., filed March 25, 1991. The issue for decision is whether the Court has jurisdiction to determine at the partnership level whether the adjustments made on the notices of final partnership administrative adjustment are attributable to...
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