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CRESCENT HOLDINGS, LLC v. COMMISSIONER

Docket Nos. 23756-11, 23757-11.

141 T.C. 477 (2013)

CRESCENT HOLDINGS, LLC, ARTHUR W. FIELDS AND JOLEEN H. FIELDS, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 2, 2013.

Attorney(s) appearing for the Case

James R. Kelley and William T. Ramsey , for petitioners.

Jasper G. Taylor III , Richard L. Hunn , and Michelle A. Spiegel , for intervenor.

W. Benjamin McClendon and Kirk Chaberski , for respondent.

RUWE, Judge:

Respondent issued a notice of final partnership administrative adjustment (FPAA) for the taxable year 2006 and an FPAA for the taxable year 2007 to Crescent Holdings, LLC (Crescent Holdings). Arthur Fields (petitioner), a partner other than the tax matters partner, filed petitions for readjustment of partnership items under section 6226.1 The cases were consolidated for trial, briefing, and opinion.

The issues...

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