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SALINA PARTNERSHIP LP v. COMMISSIONER

Docket No. 25084-96.

80 T.C.M. 686 (2000)

T.C. Memo. 2000-352

Salina Partnership LP, FPL Group, Inc., A Partner Other Than The Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed November 14, 2000.

Attorney(s) appearing for the Case

Robert T. Carney and Paul S. Manning, for the petitioner. Sergio Garcia-Pages, John T. Lortie, and Gary F. Walker, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent issued a notice of final partnership administrative adjustment (FPAA) to Caraville Corporation, N.V., the tax matters partner (TMP) of Salina Partnership, LP (hereinafter, Salina or the partnership), setting forth adjustments to the partnership's tax return for its taxable year ended December 31, 1992. Respondent subsequently mailed a copy of the FPAA to FPL Group, Inc. (FPL or petitioner...

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