MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Respondent issued petitioner a notice of final partnership administrative adjustment (FPAA) on behalf of Arbor Towers Associates, Ltd. (Arbor), wherein respondent determined Arbor was not entitled to its claimed charitable contribution deduction in the amount of $1.6 million for 1993. This case results from petitioner's petition under section 6226
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