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INTERHOTEL COMPANY, LTD. v. COMMISSIONER

Docket No. 13017-95.

74 T.C.M. 819 (1997)

T.C. Memo. 1997-449

Interhotel Company, Ltd., Torrey Hotel Enterprises, Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed September 30, 1997.

Attorney(s) appearing for the Case

J. Clancy Wilson, San Diego, Calif., for the petitioner. Paul B. Burns and Gretchen A. Kindel, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent issued a notice of final partnership administrative adjustment (FPAA) on April 11, 1995. In relevant part,1 respondent proposed increasing by $814,296 the reported distributive share of allowable ordinary income of Douglas F. Manchester (Mr. Manchester) with respect to Interhotel Co., Ltd. (IHCL), a California limited partnership, for the taxable year 1991. As...

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