MEMORANDUM OPINION
GOEKE, Judge.
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. At issue is whether this Court has jurisdiction over items respondent adjusted in the notice of deficiency relating to Bradley A. Morgan's (petitioner) investment in a partnership. We do not decide the issue with respect to the majority of the items because of the uncertainty of whether TEFRA procedures in sections 6221-6234 apply...
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