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UTAH BIORESEARCH 1984, LTD. v. COMMISSIONER

Docket No. 26091-88.

58 T.C.M. 676 (1989)

T.C. Memo. 1989-612

Utah Bioresearch 1984, Ltd., Copious Investments, Robert H. and Carolee Harmon Family Trust, Leroy C. Taylor and Elaine Barton, Partners Other Than the Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed November 13, 1989.

Attorney(s) appearing for the Case

Rand M. Elison, 215 S. State St., Salt Lake City, Utah, for the petitioners. David L. Miller, Marion K. Mortensen and Henry Schneiderman, for the respondent.

Memorandum Opinion

PANUTHOS, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443.1 This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. The issue for decision is whether the petition for readjustment of partnership items in this case must be dismissed for lack of jurisdiction because (1) the petition was not timely filed pursuant to section 6226 or (2) the notice...

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