MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Chief Judge:
By notice of final partnership administrative adjustment dated July 8, 1988, respondent increased the taxable income of Research Two Limited Partnership (Research II) as follows:
Year Amount 1982 $2,806,250 1983 233,061 1984 148,897
Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the years in...
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