- 23 - 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 regulationsPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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