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G-5 INV. PSHIP. v. COMMISSIONER

Docket No. 17767-06.

128 T.C. 186 (2007)

128 T.C. No. 15

G-5 INVESTMENT PARTNERSHIP, H. MILES INVESTMENTS, LLC, TAX MATTERS PARTNER, AND HENRY M. GREENE AND JULIE M. GREENE, PARTNERS OTHER THAN THE TAX MATTERS PARTNER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 30, 2007.

Attorney(s) appearing for the Case

Denis J. Conlon and Steven S. Brown, for petitioners.

William F. Castor, for respondent.

OPINION

HAINES, Judge:

This case is a partnership-level action based on a petition filed pursuant to section 6226.1 The sole issue raised by petitioners' motion for judgment on the pleadings is whether the period of limitations for making assessments of income tax against individual partners, relative to partnership items, has expired pursuant to sections 6501 and 6229.

The following facts are based upon the parties...

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