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3-KOAM COMPANY v. COMMISSIONER

Docket No. 4232-95.

73 T.C.M. 2415 (1997)

T.C. Memo. 1997-148

3-Koam Company, A Partnership, My Hat, Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed March 20, 1997.

Attorney(s) appearing for the Case

David M. Kirsch, San Jose, Calif., for the petitioner. Kimberley J. Peterson, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge:

3-Koam Company partnership (3-Koam), My Hat, Inc. (My Hat or petitioner), Tax Matters Partner, petitioned the Court under section 6226 to readjust respondent's adjustments of partnership items flowing from the partnership. By notice of final partnership administrative adjustment (FPAA) dated February 16, 1995, respondent determined adjustments to items claimed on 3-Koam's 1990 U.S. Partnership Return of...

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