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PALM CANYON X INVESTMENTS, LLC v. COMMISSIONER OF INTERNAL REVENUE

No. 5610-06.

T.C. Memo. 2009-288

PALM CANYON X INVESTMENTS, LLC, AH INVESTMENT HOLDINGS, INC., TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 15, 2009.

Attorney(s) appearing for the Case

Steven R. Mather and Lydia B. Turanchik, for petitioner.

Stephen M. Barnes, William R. Davis, Jr., Dennis M. Kelly, and David W. Sorensen, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge.

Respondent issued a notice of final partnership administrative adjustment (FPAA) for 2001 pursuant to section 6223(a)1 to AH Investment Holdings, Inc. (AHI), the tax matters partner (TMP) of Palm Canyon X Investments, LLC (Palm Canyon),2 a limited liability company classified as a partnership for Federal income tax purposes.3...

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