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AHG INVS., LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 3745-09.

140 T.C. 73 (2013)

AHG INVESTMENTS, LLC, ALAN GINSBURG, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 14, 2013.

Attorney(s) appearing for the Case

Thomas A. Cullinan, for petitioner.

George W. Bezold, for respondent.

OPINION

GOEKE, Judge:

This case is before the Court on petitioner's motion for partial summary judgment filed pursuant to Rule 121,1 to which respondent objects. Respondent issued a notice of final partnership administrative adjustment (FPAA) to petitioner, a partner other than the tax matters partner (TMP) of AHG Investments, LLC (AHG Investments). The major adjustment in the FPAA was to disallow $10,069,505 in losses...

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