T.C. Memo. 1997-246
UNITED STATES TAX COURT
NEW ORLEANS LOUISIANA SAINTS, LIMITED PARTNERSHIP, BENSON
FOOTBALL, INC., TAX MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2632-94. Filed June 2, 1997.
Douglas D. Drysdale, Trevor W. Swett III, and Matthew W.
Frank, for petitioner.
Derek B. Matta, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge: Respondent issued five notices of final
partnership administrative adjustments to petitioner, determining
adjustments for taxable years 1985 through 1989. After
concessions by the parties, the sole issue for consideration is
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