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On their 1983 return, Josephine and Anthony claimed an
ordinary loss in the amount of $10,477 and an investment tax
credit in the amount of $18,578 with respect to their $25,000
investment. Since the alternative minimum tax nullified the
entire benefit of the investment tax credit for 1983, Josephine
and Anthony filed amended returns for 1980 and 1981 to carry back
portions of the 1983 credit to offset their previously reported
tax liability for the 1980 and 1981 taxable years.
Pursuant to the agreement of the parties in the underlying
partnership proceeding, this Court entered a stipulated decision
on February 17, 1995, which decided that the none of the losses
claimed by Barrister partnership for 1983 and 1984 were allowed
and the amounts of its qualified investment credit property for
1983 and 1984 were zero.3 Respondent thereafter made
computational adjustments disallowing the losses and investment
tax credits claimed by petitioners with respect to the Barrister
partnership.
The first issue for decision is whether respondent properly
notified petitioners of the Barrister partnership proceeding for
its 1983 and 1984 taxable years. We have jurisdiction in these
cases to decide whether respondent complied with the notice
requirements of section 6223(a) allowing petitioners the
3 Anderson Equipment Associates, et al, Barrister
Associates, Tax Matters Partner v. Commissioner, docket No.
27745-89.
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