Memorandum Findings of Fact and Opinion
HALPERN, Judge:
Respondent, in a notice of final partnership administrative adjustment (FPAA), determined adjustments to the partnership return of $3,296,578 and $11,559.58 with respect to Scarsdale Oil Associates, 1983A's 1983 and 1984 taxable years, respectively. Those amounts, in their entirety, remain in dispute.
Scarsdale Oil Associates, 1983A (Scarsdale 1983A or the partnership) had its principal place...
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