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LANZI v. ALABAMA DEPT. OF REVENUE

2040298.

968 So.2d 18 (2006)

Joe E. LANZI III v. ALABAMA DEPARTMENT OF REVENUE.

Court of Civil Appeals of Alabama.

Certiorari Denied April 13, 2007.

Attorney(s) appearing for the Case

David M. Wooldridge, Anthony R. Smith, and Donald E. Johnson of Sirote & Permutt, P.C., Birmingham, for appellant.

Troy King, atty. gen.; and Henry C. Chappell, chief counsel, Department of Revenue, and deputy atty. gen.; and David E. Avery III and Glenmore Powers II, asst. counsel and asst. attys. gen., Department of Revenue, for appellee.

Bruce P. Ely and Matthew S. Houser of Bradley Arant Rose & White, LLP, Birmingham, for amicus curiae Alabama Society of Certified Public Accountants, in support of the appellant.

Alabama Supreme Court 1051475.

PER CURIAM.

The facts underlying this appeal are as follows. Joe E. Lanzi III ("the taxpayer") is a resident of Georgia and a limited partner of the Quad-L Limited Partnership ("Quad-L" or "the partnership"), an Alabama limited partnership. Quad-L was formed in 1996, at which time the taxpayer made an initial contribution to Quad-L in exchange for his partnership interest; the taxpayer holds a five-eighths ownership interest...

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