MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
On May 29, 1998, respondent issued Whitehouse Partners (Whitehouse) two notices of final partnership administrative adjustment that reflected adjustments to Whitehouse's partnership returns for the taxable years that ended December 31, 1993 and 1994. On June 12, 1998, Harry Olstein, Whitehouse's tax matters partner, petitioned the Court to redetermine respondent's adjustments to partnership items. Whitehouse...
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