MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice of final partnership administrative adjustment dated January 8, 1991, respondent determined adjustments to items claimed on 70 Acre Recognition Equipment Partnership's 1983 return. Unless otherwise indicated, all section references are to the Internal Revenue Code for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the sole...
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