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BROOKES v. COMMISSIONER

Docket No. 11770-96.

108 T.C. 1 (1997)

LAWRENCE V. AND KATHERINE T. BROOKES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 2, 1997.

Attorney(s) appearing for the Case

Lawrence V. Brookes, for petitioners.

Allan D. Hill, for respondent.

OPINION

GERBER, Judge:

Respondent issued a notice of deficiency for petitioners' 1980 and 1983 tax years, determining additions to tax attributable to petitioners' partnership interest in Barrister Equipment Associates Series 122, a limited partnership (Barrister). The notice of deficiency was issued following the conclusion of a partnership proceeding involving Barrister's 1983 and 1984 taxable years. In the parlance of partnership proceedings, additions...

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