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Davenport is a limited partnership subject to the unified
partnership audit and litigation procedures set forth in sections
6221 through 6233, added to the Code by the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),
96 Stat. 648.
Respondent issued notices of beginning of administrative
Proceeding (NBAP) to Davenport for the years 1982, 1983, 1984,
and 1985 on September 11, 1984, November 8, 1984, January 29,
1987, and October 27, 1986, respectively. Copies of those NBAP's
were issued to all notice partners of Davenport, including
participants. On May 15, 1989, respondent issued notices of
final partnership administrative adjustment (FPAA) to Davenport,
proposing adjustments to Davenport's 1982 through 1985 years.
The notices of FPAA were mailed to Winer as TMP, as well as to
participants and all other notice partners for the 1982 through
1985 years of Davenport.
On June 9, 1989, a petition for readjustment for the years
1982 through 1985 was filed with this Court on behalf of
Davenport by Winer, who identified himself as the TMP. When the
petition was filed in this case, Davenport had its principal
place of business in Clearwater, Florida, and participants
resided in Oak Brook, Illinois.
This case subsequently was concluded before trial by a
concession at the partnership level of the adjustments proposed
by respondent. The case was conceded at the instruction of
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