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MIDCONTINENT DRILLING ASSOCIATES v. COMMISSIONER

Docket No. 6060-92.

67 T.C.M. 2453 (1994)

T.C. Memo. 1994-119

Midcontinent Drilling Associates, a Limited Partnership, Guy Farmer, a Partner Other Than the Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed March 23, 1994.

Attorney(s) appearing for the Case

Guy Farmer, pro se.1

Alan S. Kline, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge.

Respondent made final partnership administrative adjustments to the income of Midcontinent Drilling Associates, A Limited Partnership (MCDA), of $4,249,441 for 1983, $365,895 for 1984, and $1,233,201 for 1985. Guy Farmer, petitioner, was a limited partner in MCDA.

We must decide the following issues:

1. Whether application of the TEFRA partnership provisions in this case violates petitioner...

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