Memorandum Findings of Fact and Opinion
Clapp, Judge:
Depot Investors, Ltd. (the partnership), is an Oregon limited partnership for which the provisions of sections 6221-6233 are applicable. On April 23, 1990, respondent issued a notice of final partnership administrative adjustment (FPAA) to the partnership's tax matters partner, GAF Development Co. (GAF). The explanation of items form attached to the FPAA proposed the following adjustments to the partnership...
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