Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent proposed adjustments to partnership items of Sealy Power, Ltd. (the partnership), pursuant to the partnership audit and litigation procedures of sections 6221-6233 with respect to taxable years 1983 and 1984. The proposed adjustments are as follows:
1983 Taxes ................................... $ 58,792 Depreciation ..........................
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