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shall rest exclusively with the General Partners.” Furthermore,
petitioners executed a power of attorney that provided that the
attorney-in-fact shall have the “authority to act in * * *
[their] name[s] and on * * * [their] behalf in the * * * filing
of * * * [a]ny other instrument which may be required to be filed
by the Partnership * * * or by any governmental agency * * *.”
Morever, with respect to the date of the formation of the
partnership, petitioners’ hands are not exactly clean: They
admit that they backdated documents indicating that their
interest in the partnership commenced in July 1982, and they
claimed tax deductions and credits predicated on that
representation at least in part. In these circumstances, in
order to disregard the records of the partnership, we would
require a much stronger showing than the innuendo based on
innuendo that petitioners argue here. See Estate of Durkin v.
Commissioner, 99 T.C. 561 (1992).
An appropriate order denying
petitioners’ Motion to Dismiss for
Lack of Jurisdiction will be issued.
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