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$123,000 for 1984. In Investment Engineers, Ltd. v.
Commissioner, T.C. Memo. 1994-255, we concluded that the statute
of limitations did not bar assessments pursuant to the FPAA.
Remaining for decision is whether the partnership is entitled to
deductions claimed under section 174 in the amounts adjusted by
respondent. Unless otherwise indicated, all section references
are to the Internal Revenue Code in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. The
history of management of the partnership is set forth in T.C.
Memo. 1994-255. Subsequent to that opinion, respondent filed a
Motion to Appoint a Tax Matters Partner. Robert L. Montelius,
Jr. (Montelius), was appointed tax matters partner solely for the
purpose of these proceedings.
The partnership was formed in December 1982. The promoter
of the partnership was Gregory A. Knox (Knox). Knox had a juris
doctor degree, but was not admitted to any bar, and made his
living as a financial planner.
The partnership was created by a Limited Partnership
Agreement dated December 14, 1982. The stated purpose of the
partnership was to engage in the business of research and
experimentation for the development of computer software in the
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