MEMORANDUM OPINION
COHEN, Judge:
Respondent issued a Notice of Final Partnership Administrative Adjustment (FPAA) for 1990 for CC&F Western Operations Limited Partnership (Western). CC&F Investors, Inc. (petitioner), the designated tax matters partner for Western, filed a Petition for Readjustment of Partnership Items Under Code Section 6226. After concessions, the sole remaining issue is whether disclosures made in the 1990 Federal income tax returns...
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