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DYNAMO HOLDINGS LTD. P'SHIP v. COMMISSIONER

Docket Nos. 2685-11, 8393-12.

150 T.C. 224 (2018)

150 T.C. No. 10

DYNAMO HOLDINGS LIMITED PARTNERSHIP, DYNAMO, GP, INC., TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. BEEKMAN VISTA, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 7, 2018.

Attorney(s) appearing for the Case

Martin R. Press, Edward A. Marod, Clinton R. Losego, Lu-Ann M. Dominguez, Alan S. Lederman, and John W. Terwilleger, for petitioners.

David B. Flassing, Lisa M. Goldberg, William G. Merkle, Timothy A. Sloane, and G. Roger Markley, for respondent.

The issue before us is whether we should grant the Commissioner's motion to reopen the record to receive further evidence concerning supervisory approval of the penalties that are at issue. In deciding this issue, we must confront the question of whether the Commissioner bears the burden of...

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