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DOCTORS HOSPITAL REAL ESTATE, LTD. v. COMMISSIONER

Docket No. 20343-91.

67 T.C.M. 2591 (1994)

T.C. Memo. 1994-143

Doctors Hospital Real Estate, Ltd., Doctors Hospital Management Co., Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed March 31, 1994.

Attorney(s) appearing for the Case

Thomas E. Redding and Charles B. Koerth, for the petitioner. Carol Bingham McClure and John Eiman, for the respondent.

Memorandum Findings of Fact and Opinion

LARO, Judge:

Respondent issued Doctors Hospital Management Co. (petitioner), as tax matters partner of Doctors Hospital Real Estate, Ltd. (DHRE), three notices of final partnership administrative adjustment (FPAA's). Collectively, the FPAA's covered DHRE's 1984 through 1986 taxable years. In the FPAA for 1984, respondent made an adjustment of $2,253,579 to DHRE's ordinary income, made an adjustment of $1,162,768.55...

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