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WISE GUYS HOLDINGS, LLC v. COMMISSIONER

Docket No. 6643-12.

140 T.C. 193 (2013)

WISE GUYS HOLDINGS, LLC, Peter J. Forster, Tax Matters Partner, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 22, 2013.

Attorney(s) appearing for the Case

Peter J. Forster, pro se.

Joy E. Gerdy Zogby and Paul T. Butler , for respondent.

OPINION

THORNTON, Judge:

This is a partnership-level proceeding under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648.1 Petitioner commenced this case on March 12, 2012, by filing with the Court a petition allegedly pursuant to section 6226(a)(1) or (b)(1).2 Petitioner is the tax matters partner (TMP) of Wise Guys Holdings, LLC...

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