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OLSEN-SMITH, LTD. v. COMMISSIONER

Docket No. 22081-03.

90 T.C.M. 64 (2005)

T.C. Memo. 2005-174

Olsen-Smith, LTD. v. Commissioner.

United States Tax Court.

July 18, 2005.

Attorney(s) appearing for the Case

Brad S. Ostroff and Martha Combellick Patrick (specially recognized), for petitioner.

Anne W. Durning, for respondent.

MEMORANDUM OPINION

LARO, Judge:

This case is a partnership-level proceeding subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 401, 96 Stat. 628. Smith-Olsen, PLC (Smith/Olsen), the tax matters partner of Olsen-Smith, LTD (LTD), petitioned the Court to readjust partnership items relating to a Notice of Final Partnership Administrative Adjustment (FPAA) issued...

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