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PAE ENTERPRISES v. COMMISSIONER

Docket No. 21636-87.

55 T.C.M. 875 (1988)

T.C. Memo. 1988-222

PAE Enterprises, Patrick Moretti, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed May 17, 1988.

Attorney(s) appearing for the Case

Allan P. Harris, 1776 Century Blvd., Atlanta, Ga., for the petitioner. Henry S. Schneiderman, for the respondent.

Memorandum Findings of Fact and Opinion

POWELL, Special Trial Judge:1

This case is before us on the parties, cross-motions to dismiss for lack of jurisdiction. Respondent's motion raises the question whether Patrick Moretti was the tax matters partner of PAE Enterprises within the meaning of section 6231(a)(7).2 Petitioner's motion raises the question whether, assuming that Patrick Moretti was the...

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