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ROME I, LTD. v. COMMISSIONER

Docket Nos. 13017-88, 8590-89.

96 T.C. 697 (1991)

ROME I, LTD., E.C. SYSTEMS, INC., TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 2, 1991.

Attorney(s) appearing for the Case

Donald F. Wood, George M. Gerachis, Christine C. Bland, and Kathryn V. Garner, for the petitioner.

Bonnie L. Cameron and Albert A. Balboni, for the respondent.

OPINION

COLVIN, Judge:

This is a proceeding pursuant to section 6226 for a readjustment of partnership items of Rome I, Ltd., a partnership, for the taxable year ending December 31, 1984. The facts of this case have been fully stipulated, and are so found. The relevant facts are summarized below.

After concessions, the sole issue in this case is whether the partnership must recapture a portion of the rehabilitation tax credit and reduce its...

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