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RHONE-POULENC SURFACTANTS AND SPECIALTIES, L.P. v. COMMISSIONER

Docket No. 2125-98.

114 T.C. 533 (2000)

RHONE-POULENC SURFACTANTS AND SPECIALTIES, L.P., GAF CHEMICALS CORPORATION, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 29, 2000.

Attorney(s) appearing for the Case

Albert H. Turkus, Pamela F. Olson, William F. Nelson, and Anne E. Collier, for petitioner.

John A. Guarnieri, Craig Connell, and Ruth M. Spadaro, for respondent.

OPINION

RUWE, Judge:

This case is a partnership-level action based on a petition filed pursuant to section 6226.1 Section 6226 is one of a group of provisions concerning the tax treatment of partnership items that was added to the Code by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648 (TEFRA partnership provisions).2 The matter before...

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