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GROSSMAN v. COMMISSIONER

Docket No. 22864-86.

55 T.C.M. 1155 (1988)

T.C. Memo. 1988-278

George Grossman and Gertrude R. Grossman v. Commissioner.

United States Tax Court.

Filed June 27, 1988.

Attorney(s) appearing for the Case

Curtis Berner, for the petitioners. Shelley Ann Chang, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

This case is before us on petitioners' motion to dismiss for lack of jurisdiction. Petitioners allege that the notice of deficiency is invalid because respondent failed to comply with the partnership audit and litigation procedures, section 6221 et seq.1 The sole issue for our determination is whether the partnership came into existence after September 3, 1982, thereby subjecting...

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