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  5. 131 T.C. No. 14
 

PCMG TRADING PARTNERS XX v. COMMISSIONER OF INTERNAL REVENUE

No. 5078-08, NO. 5149-08, Nos. 5150-08, 5151-08, 5152-08, 5153-08, 5154-08

131 T.C. No. 14

PCMG TRADING PARTNERS XX, L.P., DAVID BOYER, DONALD DEFOSSET, JR., RICHARD M. KELLEHER, MICHAEL ROWNY AND JOHN A. MCMULLEN, PARTNERS OTHER THAN THE TAX MATTERS PARTNER, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 11, 2008.

Attorney(s) appearing for the Case

N. Jerold Cohen and Thomas A. Cullinan, for petitioners.

Bonnie L. Cameron, for respondent.

OPINION

RUWE, Judge:

These seven cases were consolidated for purposes of considering respondent's motions to dismiss the six cases bearing docket Nos. 5149-08, 5150-08, 5151-08, 5152-08, 5153-08, and 5154-08, for lack of jurisdiction pursuant to section 6226(b)(2) and (4).2

Background

On October 3, 2007, pursuant to section 6223(a)(2), respondent issued a notice of final partnership administrative adjustment...

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