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AFFILIATED EQUIPMENT LEASING v. COMMISSIONER

Docket No. 364-91.

97 T.C. 575 (1991)

AFFILIATED EQUIPMENT LEASING II, CHARLES E. KUNZ, JOHN C. MILLER, II, GORDON B. MILLER, JR., AND JACK KING, EACH OF WHOM ARE PARTNERS OTHER THAN THE TAX MATTERS PARTNER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 20, 1991.

Attorney(s) appearing for the Case

Thomas C. Rink and Cynthia A. Fazio, for the petitioners.

Terry Serena, for the respondent.

OPINION

NIMS, Chief Judge:

This matter is before the Court on petitioners' motion to reconsider granting of respondent's motion to dismiss for lack of jurisdiction and to strike with respect to section 6621(c), I.R.C., filed March 25, 1991. The issue for decision is whether the Court has jurisdiction to determine at the partnership level whether the adjustments made on the notices of final partnership administrative adjustment are attributable to...

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