- 27 - participation in the Partnership's activities) which are determinative of respondent's right to assess deficiencies and penalties, or petitioners' right to claim overpayments for the years at issue, among other things, must be resolved in future proceedings. To reflect the foregoing, An appropriate order granting petitioners' motion for leave to file amendment to petition and respondent's motion for leave to file amendment to answer, and denying petitioners' motion for summary judgment, will be issued.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
Last modified: May 25, 2011