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LEATHERSTOCKING 1983 PARTNERSHIP v. COMMISSIONER

Docket No. 2753-98.

92 T.C.M. 106 (2006)

T.C. Memo. 2006-164

Leatherstocking 1983 Partnership, Sam I. Brown, a Partner Other Than the Tax Matters Partner v. Commissioner.

United States Tax Court.

August 14, 2006.

Attorney(s) appearing for the Case

Richard J. Sapinski and Edward A. Vrooman,1 for petitioner.

Shawna A. Early, Gerard Mackey, and Tamara L. Kotzker, for respondent.

Richard J. Sapinski and Edward A. Vrooman,1 for petitioner.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

This case is a partnership-level proceeding subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 401, 96 Stat. 648. Sam I. Brown, a partner other than the tax matters partner of Leatherstocking 1983 Partnership (Leatherstocking), petitioned the Court to readjust partnership items respondent adjusted for 1983 and 1984...

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