Memorandum Findings of Fact and Opinion
PARR, Judge:
This cause is before us on petitioners' motion to dismiss for lack of jurisdiction. Petitioners claim that we lack jurisdiction over the deficiency determination relative to the ordinary loss claimed on their 1983 Federal income tax return from MLSL Partnership, a limited partner in Liberian Forest Associates, a partnership, because respondent failed to comply with the Tax Equity and Fiscal Responsibility...
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