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partnerships’ information returns. This was established before
1958, when the Supreme Court ruled in Colony, Inc. We have no
reason to believe that the standards for respondent’s work on the
1st-tier partnerships’ information returns were intended to be
any different from those applicable to the taxpayers’ tax
returns. Given that these obligations exist as to the 1st-tier
partnerships’ information returns, we do not see any principled
basis for concluding that the 2d-tier partnerships’ information
returns require so heightened a level of examination or audit,
that our analysis of the law ought to be affected by that
heightened level. Respondent’s brief, almost afterthought,
speculation is far short of a cogent argument that principled
distinction can be drawn between 1st-tier partnerships’
information returns and all 2d-tier partnerships’ information
returns.
We do not change our analysis on account of respondent’s
warning.
Our holding in this opinion will be incorporated into the
decision to be entered in these cases when all the other issues
are resolved.14
14The parties’ stipulations and stipulated exhibits are not
treated as exhausting the record as to the subject matter of the
instant opinion. In further proceedings, the parties will be
free to provide such additional evidence on this subject matter
as is not inconsistent with our holdings and is otherwise
admissible. See also Reis v. Commissioner, 142 F.2d 900, 902,
903 (6th Cir. 1944), affg. 1 T.C. 9 (1942), as modified by a
Memorandum Opinion of this Court dated June 4, 1943.
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