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MONETARY II LTD. PARTNERSHIP v. C.I.R.

No. 93-70384.

47 F.3d 342 (1995)

MONETARY II LIMITED PARTNERSHIP, J. Thomas Hannan, Tax Matters Partner, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 2, 1995.

Attorney(s) appearing for the Case

Curtis W. Berner, Buell & Berner, San Francisco, CA, for petitioner-appellant.

Sarah K. Knutson, U.S. Dept. of Justice, Washington, DC, for respondent-appellee.

Before: LAY, PREGERSON, and O'SCANNLAIN, Circuit Judges.

O'SCANNLAIN, Circuit Judge:

We must decide whether a former partner can consent to extend the limitations period for the assessment of federal income tax attributable to the partnership's activities.

I

Monetary II Limited Partnership ("Monetary" or "the partnership") is a California limited partnership that invests in oil and gas properties. At its formation, the partnership had only two general partners, Arthur Lachman and Richard W. Naumann, each...

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