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SENTE INV. CLUB PARTNERSHIP OF UTAH v. COMMISSIONER

Docket No. 21056-87.

95 T.C. 243 (1990)

SENTE INVESTMENT CLUB PARTNERSHIP OF UTAH, WARREN ROY TOLSEN, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 11, 1990.

Attorney(s) appearing for the Case

Peter H. Waldo, for the petitioner.1

William A. Heard, III, and R. Alan Lockyear, for the respondent.

OPINION

RUWE, Judge:

This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.2 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

PANUTHOS, Special Trial Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction...

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