MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge.
This case is a partnership-level proceeding subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, sec. 402, 96 Stat. 648. Shant S. Hovnanian (Mr. Hovnanian), as the tax matters partner of Rovakat, LLC (Rovakat), petitioned the Court to readjust partnership items that respondent adjusted for Rovakat's 2002 through 2004 taxable years...
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