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2. Elliot I. Miller and Myra K. Miller, Petitioner
v. Commissioner of Internal Revenue, Respondent,
Docket No. 10383-86
3. *Leo Fine and Judith H. Fine, Petitioners
v. Commissioner of Internal Revenue, Respondent,
Docket No. 35437-85
* * * * * * *
* New controlling case:
Harold M. Provizer and Joan Provizer, Petitioners
v. Commissioner of Internal Revenue, Respondent,
Docket No. 27141-86.
On January 20, 1989, on behalf of SAB Foam, Becker
submitted the following notice to respondent:
In our protest dated September 28, 1988, we stated
that the Partnership agreed to be bound by the lead
cases (Fine, Miller and Miller).
Due to various changes in circumstances including
but not limited to a settlement of all such then
pending lead cases, the Partnership hereby withdraws
its statement to be bound by such cases or any other
case.
Becker mailed this notice by certified mail, return receipt
requested, and signed it “Stuart Becker, Tax Matters Partner”.
On December 9, 1991, respondent issued a notice of final
partnership administrative adjustment (FPAA) to SAB Management
for 1982. In the FPAA, respondent disallowed all items of
income, losses, deductions, and credits reported with respect to
SAB Foam’s equipment leasing activities for 1982. Accordingly,
respondent: (1) Increased ordinary income by $662,556; (2)
determined that SAB Foam’s investment and business energy tax
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