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These cases were consolidated for briefing and opinion, and
were submitted fully stipulated pursuant to Rule 122. The
stipulated facts are so found.
Petitioners resided in New Hyde Park, New York, when they
filed their petitions in these cases.
For the years in issue, Leo Goldman (petitioner) was a
limited partner in Mid Continent Drilling Associates II (MCDA
II). The additions to tax in issue relate to petitioner's
investment in MCDA II. MCDA II is one of several limited
partnerships which comprise respondent's Petro-Tech National
Litigation Project. Cf. Webb v. Commissioner, T.C. Memo. 1990-
556.
The Form 1065 partnership returns filed by MCDA II for
taxable years 1983 and 1984 indicate that MCDA II had more than
100 partners during each of those years. The returns show that
petitioner held a 0.00765306 profit-sharing percentage interest
in MCDA II for both 1983 and 1984. The returns also indicate
that MCDA II's employer identification number (EIN) was 13-
3093089.
On October 21, 1991, respondent timely mailed separate
Notices of Final Partnership Administrative Adjustment (FPAA),
one for taxable year 1983 and one for taxable year 1984, to the
tax matters partner (TMP) of MCDA II, and to Robert and Wendy
Lax. As reflected in MCDA II's partnership returns, Robert Lax
owned a 0.01020408 profit-sharing percentage interest in MCDA II
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