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SIH PARTNERS, LLLP v. COMMISSIONER

Docket No. 3427-15.

150 T.C. 28 (2018)

150 T.C. No. 3

SIH PARTNERS, LLLP, EXPLORER PARTNER CORPORATION, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 18, 2018.

Attorney(s) appearing for the Case

Mark D. Lanpher , Robert A. Rudnick , and Kristen M. Garry , for petitioner.

Jeffrey B. Fienberg , Richard A. Rappazzo , and Julie Ann P. Gasper , for respondent.

OPINION

On November 10, 2014, respondent issued two notices of final partnership administrative adjustment (FPAAs) to Explorer Partner Corp. (Explorer Corp.) as tax matters partner for SIH Partners LLLP (SIHP) for tax years 2007 and 2008. In the FPAAs respondent determined that SIHP has income inclusions under sections 951...

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