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FIRST BLOOD ASSOCIATES v. COMMISSIONER

Docket Nos. 623-92, 13014-92, 15641-92, 12062-94.

75 T.C.M. 2565 (1998)

T.C. Memo. 1998-228

First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. v. Commissioner.

United States Tax Court.

Filed June 29, 1998.

Attorney(s) appearing for the Case

Sallie W. Gladney, New York, N.Y., for the participants Joseph E. and Bernice L. Goodwin. Gerald A. Thorpe, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

POWELL, Special Trial Judge:

These consolidated cases are before the Court on participants Joseph E. and Bernice L. Goodwin's (the Goodwins) motion to dismiss for lack of jurisdiction. The underlying dispute arises from the Goodwins' interest in First Blood Associates (First Blood or the partnership). The parties agree that for the partnership taxable years in issue the partnership is subject to the unified audit and...

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