- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011