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  5. 132 T.C. No. 17
 

COUNTRYSIDE LIMITED PARTNERSHIP v. COMMISSIONER OF INTERNAL REVENUE

Nos. 3162-05, 22023-05, 2176-08, 2178-08

132 T.C. No. 17

COUNTRYSIDE LIMITED PARTNERSHIP, CLP HOLDINGS, INC., TAX MATTERS PARTNER, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 8, 2009.

Attorney(s) appearing for the Case

Richard S. Levine and Elliot Pisem, for petitioners.

Jill A. Frisch, for respondent.

OPINION

HALPERN, Judge.

These consolidated cases are partnershiplevel actions based on petitions filed pursuant to section 6226.2 We have issued a report granting participating partner Arthur M. Winn's motion for partial summary judgment in docket No. 3162-05, Countryside Ltd. Pship. v. Commissioner, T.C. Memo. 2008-3. Respondent has by two similarly styled motions (Nos. 1 and 2, the motions) moved to compel...

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