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LIFE CARE COMMUNITIES OF AMERICA, LTD. v. COMMISSIONER

Docket No. 21683-94.

87 T.C.M. 799 (2004)

T.C. Memo. 2004-5

Life Care Communities of America, Ltd., a Florida Limited Partnership, Robert W. McMichael, a Partner Other Than the Tax Matters, Partner v. Commissioner.

United States Tax Court.

Filed January 5, 2004.

Attorney(s) appearing for the Case

B. Gray Gibbs, for the petitioner.

Francis Mucciolo, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

By Notice of Final Partnership Administrative Adjustment (FPAA) dated August 8, 1994, respondent determined that the purchase and sale of partnership interests between partners Robert McMichael (petitioner), Hudson Fowler, and Raymond Smith were effective on June 30, 1990, rather than on January 13, 1989, and the correct distributive shares of partnership income, loss, deductions, and credits were determined...

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