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CARPENTER FAMILY INVS., LLC v. COMMISSIONER

No. 30833-08.

136 T.C. 373 (2011)

CARPENTER FAMILY INVESTMENTS, LLC, Carpenter Capital Management, LLC, Tax Matters Partner, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 25, 2011.

Attorney(s) appearing for the Case

Kevin T. Pearson and Eric J. Kodesch , for petitioner. Gary J. Merken , for respondent.

OPINION

WHERRY, Judge.

This case is before the Court on petitioner's motion for summary judgment filed September 28, 2009. Respondent filed an objection to petitioner's motion on November 20, 2009. Petitioner filed a memorandum in support of its motion on July 27, 2010. The issue is whether the notice of final partnership administrative adjustment (FPAA) challenged in the petition was issued before the applicable period of limitations for assessing...

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