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PARTNERS v. COMMISSIONER

Docket Nos. 19262-86, 19904-86.

71 T.C.M. 2146 (1996)

T.C. Memo. 1996-72

Meserve Drilling Partners, Regional Resources, Inc., f/k/a R&R Energy, Inc., Tax Matters Partner v. Commissioner. Columbia Energy Fund 1982, Regional Resources, Inc., f/k/a R&R Energy, Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed February 21, 1996.

Attorney(s) appearing for the Case

Robert. B. Martin, Pasadena, Calif., for the petitioner. Jack H. Klinghoffer, for the respondent.

MEMORANDUM OPINION

DAWSON, Judge:

These cases were assigned to Special Trial Judge Larry L. Nameroff pursuant to section 7443A(b)(4) of the Code and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

NAMEROFF, Special Trial Judge:

These cases are before us on motion by petitioner to dismiss for...

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