T.C. Memo. 1997-148
UNITED STATES TAX COURT
3-KOAM COMPANY, A PARTNERSHIP, MY HAT, INC., TAX MATTERS PARTNER,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4232-95. Filed March 20, 1997.
David M. Kirsch, for petitioner.
Kimberley J. Peterson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: 3-Koam Company partnership (3-Koam), My Hat,
Inc. (My Hat or petitioner), Tax Matters Partner, petitioned the
Court under section 6226 to readjust respondent's adjustments of
partnership items flowing from the partnership. By notice of
final partnership administrative adjustment (FPAA) dated February
16, 1995, respondent determined adjustments to items claimed on
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