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RANDELL v. COMMISSIONER

Docket No. 5796-93.

69 T.C.M. 2046 (1995)

T.C. Memo. 1995-98

Jack Randell v. Commissioner.

United States Tax Court.

Filed March 9, 1995.

Attorney(s) appearing for the Case

Jared J. Scharf, 11 Martine Ave., White Plains, N.Y., for the petitioner. Roland Barral, William L. Blagg, and Cheryl McInroy, for the respondent.

Memorandum Opinion

JACOBS, Judge:

This matter is before the Court on the following three motions: (1) Respondent's motion to dismiss for lack of jurisdiction and to strike partnership items; (2) respondent's motion to dismiss for lack of jurisdiction and to strike with respect to section 6621(c);1 and (3) petitioner's motion for summary judgment.

Petitioner was a limited partner, as well as a notice partner, of two partnerships...

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