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UVIADO, LLC EX REL. KHAN v. U.S. EX REL. I.R.S

Civil Action Nos. H-09-0052, H-09-0065.

755 F.Supp.2d 767 (2010)

UVIADO, LLC, by and through Shahid R. KHAN a partner other than the Tax Matters Partner, Plaintiff, v. UNITED STATES of America, by and through the INTERNAL REVENUE SERVICE, Defendant. Leman, LLC, by and through Jonction LLC a partner other than the Tax Matters Partner, Plaintiff, v. United States of America, by and through the Internal Revenue Service, Defendant.

United States District Court, S.D. Texas, Houston Division.

August 2, 2010.

Attorney(s) appearing for the Case

Linda Schulze Paine , Lawrence W. Sherlock , Chamberlain Hrdlicka et al., Houston, TX, for Plaintiff.

Grover Hartt, III , Department of Justice, Dallas, TX, Jonathan L. Blacker , Attorney at Law, Dallas, TX, Joshua David Smeltzer , Dallas, TX, for Defendant.

MEMORANDUM AND OPINION

LEE H. ROSENTHAL, District Judge.

In January 2009, two investment partnerships, Uviado, LLC and Leman, LLC, filed these lawsuits against the United States, seeking readjustment of partnership items proposed in two notices of Final Partnership Administrative Adjustment ("FPAA") issued in August 2008 by the Commissioner of the Internal Revenue Service. The issue addressed in this opinion is venue, which turns on the partnerships' principal...

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