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GAUGHF PROPS., L.P. v. COMMISSIONER

Docket No. 18298-07.

139 T.C. 219 (2012)

GAUGHF PROPERTIES, L.P., Balazs Ventures, LLC, a Partner Other Than the Tax Matters Partner, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 10, 2012.

Attorney(s) appearing for the Case

David De Coursey Aughtry and William E. Buchanan , for petitioner.

John Aletta , William Franklin Castor , and Edsel Ford Holman, Jr. , for respondent.

OPINION

GOEKE, Judge:

On March 30, 2007, respondent mailed a notice of final partnership administrative adjustment (FPAA) to the tax matters partner (TMP) for Gaughf Properties, L.P. (Gaughf Properties), concerning the tax year ended (TYE) December 27, 1999. The FPAA reflected respondent's determination that Gaughf Properties failed to recognize $4,455,000 in gross income resulting from the expiration of...

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