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filed the motion. Mr. Caldwell thereby joined this
proceeding as a participating partner. On July 27, 1994,
Mr. John P. Haddock, Jr., also submitted a Notice of
Election to Participate. The Court granted leave and
filed the election on the same date. On August 1, 1994,
Mr. Denny filed a Motion for Leave to File Notice of
Election to Intervene pursuant to Rule 245(a). By Order
dated November 3, 1994, the Court granted Mr. Denny's
motion, and he intervened in this proceeding. In acting on
Mr. Denny's motion, the Court accepted Mr. Denny's
representation that he is the tax matters partner. The
Court did not make a determination to that effect.
OPINION
The Wayne Caldwell Escrow Partnership is subject to
the unified partnership audit and litigation procedures
set forth in sections 6221 through 6231. The petition for
readjustment, filed by five partners other than the tax
matters partner, asks the Court to readjust partnership
items from the partnership for taxable year 1983.
In general, the phrase "partnership item" means any
item required to be taken into account under the Internal
Revenue Code, including the partnership's income, gain,
loss, deduction, or credit, to the extent that regulations
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