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METALS REFINING LTD. v. COMMISSIONER

Docket Nos. 11432-89, 16665-90.

65 T.C.M. 2171 (1993)

T.C. Memo. 1993-115

Metals Refining Limited, Bruce Stein, Tax Matters Partner and Virgil L. Jackson, Tax Matters Partner v. Commissioner. Metal Refining Limited, Elaine C. Levy, A Partner Other Than the Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed March 29, 1993.

Attorney(s) appearing for the Case

Bruce Stein and Virgil L. Jackson, pro se in Docket Nos. 11432-89, 16665-90. George J. Rabil and Norman E. Bayles, for M. Arthur Auslander (participating partner) in Docket Nos. 11432-89, 16665-90. Ellis L. Reemer and Dennis M. Bresnan, for John J. Dwyer (participating partner) in Docket Nos. 11432-89 and 16665-90. Michael S. Daiell, 16 Court St., Brooklyn, N.Y., for the petitioner Elaine C. Levy in Docket No. 16665-90 and participating partner Elaine C. Levy in Docket No. 11432-89. Ira B. Stechel, for participating partners James Bottari and Mario Cella in Docket No. 16665-90. William S. Garofalo, Leon R. St. Lauren, and Frank A. Racaniello, for the respondent.

Memorandum Findings of Fact and Opinion

PANUTHOS, Chief Special Trial Judge:

These cases were assigned pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183 and a partial trial held with respect to certain issues.1

Respondent issued two Notices of Final Partnership Administrative Adjustment (FPAA) with respect to partnership adjustments of Metals Refining Limited (MRL). The first FPAA, issued February...

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