OPINION
HALPERN, Judge:
I. Introduction
This case involves a petition for the readjustment of certain partnership items reported on the 1986 tax return of Crop Associates-1986, a limited partnership with its principal place of business in Coachella, California (the partnership). The petition was filed by a partner other than the tax matters partner. Frederick H. Behrens is the tax matters partner, and, on June 28, 1999, we allowed...
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