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I-TECH R&D LIMITED PARTNERSHIP v. COMMISSIONER

Docket No. 20561-97.

81 T.C.M. 1012 (2001)

T.C. Memo. 2001-10

I-Tech R&D Limited Partnership, Nathan Lewin, A Partner Other Than the Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed January 22, 2001.

Attorney(s) appearing for the Case

Nathan Lewin, pro se.

Judith Cohen, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent issued a notice of final partnership administrative adjustment letter (FPAA) for the years 1984, 1985, 1986, and 1987 to I-Tech R&D Limited Partnership (I-Tech). Nathan Lewin (petitioner), a partner other than the tax matters partner, filed a petition for readjustment of partnership items under Code section 6226.1 After concessions,2

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