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Steven Mather and Kenneth Barish, for petitioner.
William H. Quealy, Jr., Henry T. Schafer, Alan Summers,
Alcie M. Harbutte, Guy H. Glaser, Zachary King, and Ronald L.
Buch, Jr., for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: This case is presently before the Court on
petitioner’s motion for dismissal or alternative relief based on
respondent’s misconduct (the motion), filed July 2, 1999.1
Respondent objects. For the reasons stated, we shall deny the
motion.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
The Partnership
This case originates with a petition for the readjustment of
certain partnership items of Crop Associates-1986, a limited
partnership with its principal place of business in Coachella,
California, at the time the petition was filed (the partnership).
1 A prior report in this case appears at Crop Associates-
1986 v. Commissioner, 113 T.C. 198 (1999). Since that report, we
have substituted Frederick H. Behrens, Tax Matters Partner, for
W. Keith Oehlschlager, A Partner Other Than the Tax Matters
Partner, as petitioner.
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