Memorandum Opinion
BEGHE, Judge:
By notices of final partnership administrative adjustment (FPAA's), respondent determined adjustments to the partnership returns of income of T.W. Ancillary Ltd. for the taxable years 1983, 1984, and 1985. T.W. Ancillary Ltd. (the partnership) is a California limited partnership subject to the unified audit and litigation procedures for partnership items under sections 6221-6233
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