Memorandum Findings of Fact and Opinion
COHEN, Judge:
This case involves an adjustment of partnership items on partnership returns for 1982, 1983, and 1984. The only issue now before us is whether the statute of limitations bars assessments attributable to the partnership items. If petitioner prevails on this issue, petitioner will be entitled to a judgment on the merits in this case. If respondent prevails on this issue, the adjustments will be reviewed...
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