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CALTEX OIL VENTURE v. COMMISSIONER

Docket No. 3793-08.

138 T.C. 18 (2012)

CALTEX OIL VENTURE, CALTEX MANAGEMENT CORPORATION, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 12, 2012.

Attorney(s) appearing for the Case

Bernard Stephen Mark and Richard Stephen Kestenbaum, for petitioner.

Halvor N. Adams III, Margaret Burow, and James P.A. Caligure, for respondent.

OPINION

GUSTAFSON, Judge:

On November 13, 2007, the Internal Revenue Service (IRS) issued a notice of final partnership administrative adjustment (FPAA) for taxable year ending December 31, 1999, to Caltex Management Corp., the tax matters partner (TMP) of Caltex Oil Venture. (It is the latter entity—Caltex Oil Venture—to which we refer herein as "Caltex".) This case is a partnership-level action based on a petition filed by the TMP...

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