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ENVIRONMENTAL PRESERVATION COMPANY v. COMMISSIONER

Docket No. 27808-89.

63 T.C.M. 2117 (1992)

T.C. Memo. 1992-100

Environmental Preservation Company, B. Roland Freasier, Jr., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed February 19, 1992.

Attorney(s) appearing for the Case

John F. Kelly and Michael J. Kelly, for Estate of Alvin Q. Jarrett,* participating partner. William Rinquette, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

By notice of final partnership administrative adjustment dated August 21, 1989, respondent determined that Environmental Preservation Co. (EPC) on its 1984 partnership return overstated the value attributable to its charitable contribution of certain real property. Respondent also determined that the partnership interest held by one of the partners of EPC was other than reported on EPC's 1984 return...

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