Memorandum Findings of Fact and Opinion
PARR, Judge.
This matter is before the Court on petitioner's motion to dismiss for lack of jurisdiction filed December 22, 1993, pursuant to Rule 40.
In her notice of final partnership administrative adjustments (hereinafter FPAA) dated January 25, 1993, respondent determined that Sirrine Building No. 1 (Partnership) failed to report long-term capital gain for tax year 1985,
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