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THOMPSON v. COMMISSIONER

No. 30586-08.

137 T.C. 220 (2011)

RANDALL J. AND KAREN G. THOMPSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 27, 2011.

Attorney(s) appearing for the Case

Edward M. Robbins, Jr., for petitioners.

James A. Kutten, for respondent.

OPINION

WHERRY, Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. The case constitutes a partner-level action under the unified partnership audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324.1

Background

I. Partnership...

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