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MOUNT MERCY ASSOCS. v. COMMISSIONER

Docket No. 11191-90.

67 T.C.M. 2267 (1994)

T.C. Memo. 1994-83

Mount Mercy Associates, Alan Berk, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed February 24, 1994.

Attorney(s) appearing for the Case

Leonard Rosen (specially recognized), for the petitioner. Randall P. Andreozzi, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, by means of a Notice of Final Partnership Administrative Adjustment (FPAA), determined adjustments to Mount Mercy Associates', a limited partnership (partnership), income for its 1985 and 1986 taxable years in the amounts of $1,534,738 and $1,473,348, respectively. The adjustments are attributable to respondent's disallowance of deductions claimed for a charitable contribution.

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