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HENRY v. COMMISSIONER OF INTERNAL REVENUE

No. 13953-06.

132 T.C. No. 16

HENRY AND SUSAN F. SAMUELI, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 18, 2009.

Attorney(s) appearing for the Case

Nancy L. Iredale, for petitioners.

Miles B. Fuller and Louis B. Jack, for respondent.

OPINION

KROUPA, Judge.

Respondent moves the Court to dismiss part of this case for lack of jurisdiction. That part relates to petitioners' allegation of a reduction in their taxable income for 2003 on account of adjustments from H&S Ventures, LLC (H&S Ventures), a limited liability company treated as a partnership for Federal tax purposes. We lack jurisdiction if petitioners' amended individual income tax return for 2003 (amended return) did not...

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