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SPENCER MEDICAL ASSOCIATES v. COMMISSIONER

Docket No. 17212-95.

73 T.C.M. 2309 (1997)

T.C. Memo. 1997-130

Spencer Medical Associates, Automotive Ventures, Inc. f/k/a Spencer Toyota, Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed March 12, 1997.

Attorney(s) appearing for the Case

D. Christopher Ohly, Baltimore, Md., and Kevin F. Leahy, for the petitioner. Karen E. Chandler, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Chief Judge:

By Notice of Final Partnership Administrative Adjustment (FPAA) dated June 6, 1995, respondent determined an upward adjustment in Spencer Medical Associates' ordinary income for 1990 in the amount of $1,084,547. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure...

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