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For purposes of our consideration of Petitioners’
Motion for Summary Judgment, the parties have not presented
to the Court all of the documents that are pertinent to
each of the nine cases. They have attached as exhibits to
the stipulation several categories of documents that relate
to each petitioner. These include the partnership agree-
ment for each partnership, the U.S. Partnership Return of
Income filed on Form 1065 by each partnership for taxable
year ending December 31, 1989, and the FPAA issued by
respondent to each partnership. They have also attached as
exhibits to the stipulation certain other documents that
relate to one of the partnerships, Dakotah Hills Offices
Limited Partnership, in the case of docket No. 18955-93
(Dakotah Hills). As we read the Stipulation of Facts, the
parties intend the Dakotah Hills documents as exemplars of
the documents executed with respect to all of the cases.
In the following discussion, we have focused on the facts
in the Dakotah Hills case, and references to the partner-
ship are references to Dakotah Hills.
Dakotah Hills was formed by a group of four general
partners, Mr. David Randall Jenkins, Ms. Renee Jenkins,
Mr. Timothy Lee Shaftel, and the JNC Companies, an
Arizona corporation. It was established on or about
October 25, 1984, pursuant to the Uniform Limited
Partnership Act of the State of Arizona, when the Agreement
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