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CRI-LESLIE, LLC v. COMMISSIONER

Docket No. 1454-14.

147 T.C. 217 (2016)

147 T.C.No. 8

CRI-LESLIE, LLC, DONALD W. WALLACE, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 7, 2016.

Attorney(s) appearing for the Case

Leslie Joel Barnett, David L. Koche, Micah G. Fogarty, and Christopher R. Dingman, for petitioner.

Timothy A. Sloane, Andrew Michael Tiktin, and Lauren Epstein, for respondent.

OPINION

This case is a partnership-level proceeding subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648. Petitioner, Donald W. Wallace, the tax matters partner (TMP), asserts that respondent's notice of final...

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