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ASA INVESTINGS PARTNERSHIP v. COMMISSIONER

Docket No. 27320-96.

76 T.C.M. 325 (1998)

T.C. Memo. 1998-305

ASA Investerings Partnership, AlliedSignal Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed August 20, 1998.

Attorney(s) appearing for the Case

Jerome B. Libin, Washington, D.C., Steuart H. Thomson, David A. Roby, Jr., William S. Corey, Robert S. Chase II, Alexa Temple Dubert, and H. Karl Zeswitz, Jr., for the petitioner. Jill A. Frish, Anne O. Hintermeister, Leslie J. Spiegel, Peter J. Graziano, James M. Guiry, and Robert A. Baxer, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

Respondent issued ASA Investerings Partnership (ASA) a notice of final partnership administrative adjustment (FPAA) that reflected adjustments to ASA's partnership return for taxable years which ended on May 31, 1990, May 31, 1991, December 31, 1991, and June 1, 1992. On December 24, 1996, AlliedSignal Inc. (AlliedSignal), ASA's tax matters partner, petitioned the Court to redetermine respondent's adjustments...

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