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23rd CHELSEA ASSOCIATES, L.L.C. v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 22382-19.

162 T.C. No. 3

23RD CHELSEA ASSOCIATES, L.L.C., RELATED 23RD CHELSEA ASSOCIATES, L.L.C., TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 20, 2024.

Attorney(s) appearing for the Case

James P. Dawson and Alan S. Cohen , for petitioner.

Frederick C. Mutter and Mimi M. Wong , for respondent.

OPINION

On September 30, 2019, the Commissioner of Internal Revenue (Commissioner) issued a notice of final partnership administrative adjustment (FPAA) for tax year 2009 to Petitioner, Related 23rd Chelsea Associates, L.L.C., the tax matters partner (TMP) for 23rd Chelsea Associates, L.L.C. (23rd Chelsea). This case is...

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