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AHG INVS., LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 3745-09.

140 T.C. 73 (2013)

AHG INVESTMENTS, LLC, ALAN GINSBURG, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 14, 2013.

Attorney(s) appearing for the Case

Thomas A. Cullinan , for petitioner.

George W. Bezold , for respondent.

OPINION

GOEKE, Judge:

This case is before the Court on petitioner's motion for partial summary judgment filed pursuant to Rule 121,1 to which respondent objects. Respondent issued a notice of final partnership administrative adjustment (FPAA) to petitioner, a partner other than the tax matters partner (TMP) of AHG Investments, LLC (AHG Investments). The major adjustment in the FPAA was to disallow $10,069,505 in losses...

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