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HARRELL v. COMMISSIONER

Docket No. 15819-87.

91 T.C. 242 (1988)

ROBERT L. HARRELL AND ANNE N. HARRELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 17, 1988.

Attorney(s) appearing for the Case

G. Tomas Rhodus and Ronald A. Stein, for the petitioners.

James W. Lessis, for the respondent.

WHITAKER, Judge:

This cause is before us on petitioners' motion to dismiss for lack of jurisdiction.1 Petitioners claim that we lack jurisdiction over the deficiency determination against them because respondent, seeking to make adjustments with respect to a partnership, failed to issue a notice of final partnership administrative adjustment (FPAA).2 Respondent...

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