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3K INVESTMENT PARTNERS v. COMMISSIONER OF INTERNAL REVENUE

No. 3891-06.

133 T.C. No. 6

3K INVESTMENT PARTNERS, 3K INVESTMENTS LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed September 3, 2009.

Attorney(s) appearing for the Case

Albert L. Grasso and David B. Shiner, for petitioner.

R. Scott Shieldes, for respondent.

OPINION

THORNTON, Judge.

This case is before us on petitioner's motions to compel production of documents pursuant to Rules 72 and 104.1 For the reasons described below, we shall deny petitioner's motions.

Background

This partnership-level proceeding involves respondent's determination that 3K Investment Partners (the partnership) was formed and availed of to engage in a so-called Son-of-BOSS transaction.

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