T.C. Memo. 2006-164
UNITED STATES TAX COURT
LEATHERSTOCKING 1983 PARTNERSHIP, SAM I. BROWN,
A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2753-98. Filed August 14, 2006.
Richard J. Sapinski and Edward A. Vrooman,1 for petitioner.
Shawna A. Early, Gerard Mackey, and Tamara L. Kotzker, for
respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: This case is a partnership-level proceeding
subject to the unified audit and litigation procedures of the Tax
1 Edward A. Vrooman signed the petition as petitioner’s
counsel and was allowed to withdraw after Richard J. Sapinski
entered his appearance on Nov. 30, 1998.
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