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ENGLISH v. COMMISSIONER

Docket No. 21373-89.

60 T.C.M. 1601 (1990)

T.C. Memo. 1990-662

J. Walter English and Janet English v. Commissioner.

United States Tax Court.

Filed December 31, 1990.

Attorney(s) appearing for the Case

Jay J. Freireich, 256 Columbia Turnpike, Florham Park, N.J., for the petitioners. Jeffrey I. Rosenberg, Pamela V. Gibson and Rose E. Gole, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

This case is before us on several motions which will be described later in this opinion and dealt with against the following background.

During the taxable years ending December 31, 1984, and December 31, 1985, petitioners were partners in Garfield Residential Real Estate Limited Partnership 2611 (Garfield). By means of a notice of final partnership administrative adjustment (FPAA) for 1984 addressed to "Tax...

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