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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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Last modified: May 25, 2011