ALARCON, Circuit Judge:
Russell Redhouse Jr. (Redhouse or taxpayer), a limited partner in Tennessee Coal Resources, Ltd. (TCR), filed a petition in the United States Tax Court seeking redetermination of deficiencies in his federal income tax for the 1976 taxable year. The Tax Court consolidated Redhouse's case with those of other TCR partners and sustained the Commissioner's determination of deficiencies. Wendland v. Commissioner,
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