Memorandum Opinion
NAMEROFF, Special Trial Judge:
This case is before the Court on motion of the participating partner for summary judgment. The participating partner contends that the notice of final partnership administrative adjustment (FPAA) issued by respondent on November 10, 1987, was mailed after the expiration of the period of limitations on April 15, 1987. This contention requires the Court to determine whether the Form 872-P, Consent to Extend...
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