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HARBOR COVE MARINA PARTNERS PSHIP. v. COMMR.

Docket No. 13267-02.

123 T.C. 64 (2004)

123 T.C. No. 4

HARBOR COVE MARINA PARTNERS PARTNERSHIP, ROBERT A. COLLINS, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 15, 2004.

Attorney(s) appearing for the Case

W. Alan Lautanen, for petitioner.

Karen Nicholson Sommers, for respondent.

OPINION

LARO, Judge:

This case is a partnership proceeding subject to the unified audit and litigation procedures of the Tax Equity & Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, 96 Stat. 324, 628. It is currently before the Court for decision without trial. See Rule 122; see also sec. 6226(b).1 When the tax matters partner of Harbor Cove Marina Partners (HCMP) did not petition this Court under section...

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