SEALY POWER, LTD. v. COMMISSIONER

Docket No. 13568-88.

63 T.C.M. 2482 (1992)

T.C. Memo. 1992-168

Sealy Power, Ltd., Donald E. Rutt, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed March 23, 1992.


Attorney(s) appearing for the Case

Ruth E. Salek, 1200 Smith St., Houston, Tex., and George W. Connelly, Jr., for the petitioner.

T. Richard Sealy, III, for the respondent.


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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