MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
The instant case is a proceeding pursuant to sections 6226-6231 for a readjustment of partnership items of Oakcross Vineyards Ltd. (Vineyards), a partnership, for the taxable year ending December 31, 1990. In a Notice of Final Partnership Administrative Adjustment, respondent increased Vineyards' income for that year by $1,625,423 and increased the partnership's self-employment income by the same amount...
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