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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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