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MERCATO GLOBAL OPPORTUNITIES FUND, LP v. COMMISSIONER OF INTERNAL REVENUE

No. 26268-09.

T.C. Memo. 2011-220

MERCATO GLOBAL OPPORTUNITIES FUND, LP, JASON CHAI, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 12, 2011.

Attorney(s) appearing for the Case

Frank Agostino and Jeremy M. Klausner , for petitioner.

Alan M. Jacobson , for respondent.

MEMORANDUM OPINION

KROUPA, Judge.

This matter is before the Court on respondent's motion for partial summary judgment filed pursuant to Rule 121.1 Respondent issued Mercato Global Opportunities Fund, LP (Mercato), two notices of final partnership administrative adjustment (FPAAs) for 2003 and 2004 (years at issue). Respondent asks this Court to hold, as a matter of law, that the FPAAs were issued before the relevant limitations...

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