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RAWLS TRADING, L.P. v. COMMISSIONER

Docket Nos. 12937-07, 12938-07, 14880-07.

138 T.C. 271 (2012)

RAWLS TRADING, L.P., RAWLS MANAGEMENT CORPORATION, TAX MATTERS PARTNER, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed March 26, 2012.

Attorney(s) appearing for the Case

Michael Todd Welty, David E. Colmenero, and Laura L. Gavioli, for petitioners.

Josh O. Ungerman, for petitioners in docket No. 14880-07.

Elaine H. Harris, David B. Flassing, Julie Ann P. Gasper, and Mark Edward O'Leary, for respondent.

VASQUEZ, Judge:

These three consolidated cases are before the Court on respondent's request to stay the proceeding in one case. The cases constitute partnership-level proceedings under the unified partnership audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648 (codified as amended at sections 6221-6233).2

Once each during two discrete...

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