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GINSBURG v. COMMISSIONER

Docket No. 13330-05.

127 T.C. 75 (2006)

127 T.C. No. 5

ALAN H. GINSBURG AND ESTATE OF HARRIET F. GINSBURG, DECEASED, ALAN H. GINSBURG, PERSONAL REPRESENTATIVE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 30, 2006.

Attorney(s) appearing for the Case

N. Jerold Cohen, Sheldon M. Kay, and Joseph M. DePew, for petitioners.

Stephen R. Takeuchi, for respondent.

OPINION

GOEKE, Judge:

This case is before us on petitioners' motions to dismiss for lack of jurisdiction and for summary judgment. The issue raised by petitioners' motion to dismiss is whether respondent's notice of deficiency properly adjusted losses attributable to a partnership at the partner level pursuant to the TEFRA provisions of sections 6221-6234.1 Specifically, the inquiry centers on whether these losses should...

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