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CITY CHIROPRACTIC, PLC. In a Decision document from
Hudspath v. Commissioner (US Tax Court, Docket No.
7901-00), agreed to and signed by both the taxpayer,
and the IRS, entered April 26, 2002 into the US Tax
Court record, the following items were stipulated:
1.) Petitioner reported certain items on his 1996
and 1997 income tax returns related on his
investment in WIN Enterprises, LC and
Stephens City Chiropractic, PLC.
2.) WIN Enterprises, LC and Stephens City
Chiropractic, PLC are partnerships which are
subject to the unified audit and litigation
procedures set forth in I.R.C. ��6221 et seq
(the TEFRA partnership procedures).
3.) For purposes of computing the overpayment in
this case, petitioner’s partnership items
relating to WIN Enterprise, LC and Stephens
City [Chiropractic], PLC have been treated as
if they were correctly reported on
petitioner’s income tax returns for the 1996
and 1997 taxable years and they have not been
adjusted as part of this docketed proceeding.
4.) The tax treatment of petitioner’s partnership
items relating to WIN Enterprise, LC and
Stephens City [Chiropractic], PLC will be
resolved in a separate partnership proceeding
conducted in accordance with the TEFRA part-
nership procedures.
5.) The adjustments necessary to apply the re-
sults of the TEFRA partnership proceeding
described in subparagraph 4 to petitioner,
shall be treated as computational adjustments
under I.R.C. � 6231(a)(6) and assessed, cred-
ited or refunded accordingly.
6.) To the extent that the computation of peti-
tioner’s tax liability which properly re-
flects the tax treatment of the partnership
items relating to WIN Enterprise, LC and
Stephens City Chiropractic, PLC, as deter-
mined in the TEFRA partnership proceeding
described in subparagraph 4, would also re-
sult in a change in petitioner’s tax liabil-
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