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NPR INVESTMENTS, LLC, EX REL. ROACH v. U.S.

No. CV 5:05-CV-219-TJW.

732 F.Supp.2d 676 (2010)

NPR INVESTMENTS, LLC, by and through Nelson J. ROACH, A Notice Partner, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Texas, Texarkana Division.

August 10, 2010.

Attorney(s) appearing for the Case

N. Jerold Cohen, Kent L. Jones, Kurt Lentz, Thomas A. Cullinan, Sutherland Asbill & Brennan, Atlanta, GA, for Plaintiff.

J. Hoke Peacock, II, Orgain Bell & Tucker, Beaumont, TX, for Plaintiff/Defendant.

Andrew L. Sobotka, US Attorney Office, Joshua David Smeltzer, Cynthia E. Messersmith, Department of Justice, Dallas, TX, for Defendant.

MEMORANDUM OPINION AND ORDER

T. JOHN WARD, District Judge.

This case is a Tax Equity and Fiscal Responsibility Act of 1982 ("TEFRA") partnership proceeding under Section 6226 of the Internal Revenue Code.1 Plaintiff NPR Investments, LLC ("NPR") filed this lawsuit seeking readjustment of certain items determined in the Internal Revenue Service's Notice of Final Partnership Administrative Adjustment (FPAA) pursuant to 26...

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