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IPO II v. COMMISSIONER

Docket No. 14500-02.

122 T.C. 295 (2004)

122 T.C. No. 17

IPO II, A PARTNERSHIP, GERALD R. FORSYTHE, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 23, 2004.

Attorney(s) appearing for the Case

David J. Duez, Thomas C. Borders, and Ann M. Chavie, for petitioner.

Jason W. Anderson, for respondent.

OPINION

HAINES, Judge:

Respondent issued a notice of final partnership administrative adjustment (FPAA) to Gerald R. Forsythe, as tax matters partner (TMP) for IPO II, determining adjustments to IPO II's Federal tax returns for 1998 and 1999 (years in issue). For clarification purposes, we shall refer to Gerald R. Forsythe in his capacity as TMP as petitioner; we shall refer to Gerald R. Forsythe in his capacity as owner of IPO II and the other entities...

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