Memorandum Findings of Fact and Opinion
PARKER, Judge:
Petitioner, a partner other than the tax matters partner, filed a petition for readjustment of partnership items under section 6226(b). Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the pertinent years before the Court, and all Rule references are to the Tax Court Rules of Practice and Procedure. On July 1, 1992, the case was heard on respondent's second...
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