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  5. 66 T.C.M. 265 (1993)
 

PNRC LTD. PARTNERSHIP v. COMMISSIONER

Docket Nos. 13897-91, 13898-91, 13899-91, 13900-91.

66 T.C.M. 265 (1993)

T.C. Memo. 1993-335

PNRC Limited Partnership, PNRC Corporation, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed July 29, 1993.

Attorney(s) appearing for the Case

Harvey N. Shapiro, 1735 Market St., Philadelphia, Pa., for the petitioner. Linda S. Bednarz, for the respondent.

Memorandum Findings of Fact and Opinion

LARO, Judge:

Respondent issued petitioner a notice of final partnership administrative adjustment (FPAA) on behalf of PNRC Limited Partnership (PNRC LP) asserting that its losses for the taxable years 1983, 1984, 1985, and 1986 were disproportionately distributed between the general partner and the limited partner.1 This case is before the Court...

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