Dakotah Hills Offices Limited Partnership, An Arizona Limited Partnership, William M. and Dianne B. Stephens, Tax Matters Partners, et al. - Page 3

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                  Ironwood Manufacturing Ltd. Partnership 918,765                     
                  Vail Commerce Center Ltd. Partnership   417,156                     

                  Petitioners' motion asserts that none of the above                  
             adjustments involves a "partnership item" as that phrase is              
             defined by section 6231.  Therefore, petitioners' motion                 
             asks the Court to dismiss all of the subject cases on the                
             ground that the Court does not have jurisdiction to                      
             readjust nonpartnership items in these proceedings                       
             commenced under the unified partnership litigation                       
             procedures set forth in sections 6221 through 6233,                      
             inclusive.                                                               

                                     Background                                       
                  According to Petitioners' Motion for Summary Judgment,              
             the operative facts in each of the nine consolidated cases               
             are similar, and are set forth in the pleadings and the                  
             revenue agent's reports attached to petitioners' motion.                 
             After argument was heard on petitioners' motion, the                     
             parties submitted a Stipulation of Facts, together with                  
             various documents attached as exhibits.  We have taken the               
             facts set forth in this opinion from the pleadings,                      
             Petitioners' Motion for Summary Judgment, and the                        
             Stipulation of Facts and attached exhibits filed by the                  
             parties.                                                                 







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