OPINION
COHEN, Judge:
In a notice of final partnership administrative adjustment (FPAA) sent October 4, 2005, respondent determined that Bakersfield Energy Partners, L.P. (BEP), had overstated its basis in certain gas reserves sold during the taxable year 1998, thus causing an understatement of partnership income by more than 25 percent of the amount stated in the return. The issue for decision is whether, under those circumstances, the overstatement...
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