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Initially, respondent separately examined the individual
returns of an indeterminate number of the entity’s 78 investors,
of which audits petitioners presumably had no knowledge, given
their representation to the IRS Service Center Interest Abatement
Coordinator that they first became aware in October 2002 that
their entity deductions were being disallowed.
Respondent determined deficiencies against the audited
putative partners, on the basis of the sham transaction doctrine.
Five individual petitions to this Court ensued, encompassing
various taxable years from 1982 to 1985. See Alhouse v.
Commissioner, supra. Our decision in Alhouse analyzed the nature
of the business relationship governing the investors vis-a-vis
the managerial agent administering the various computer equipment
transactions. We construed the investment interests as
comprising the formation of a partnership, not a tenancy in
common, for tax purposes, pursuant to the regulatory guidelines
and caselaw principles underlying section 7701(a)(2). Id. (The
aforementioned entity will hereinafter be referred to as the
Partnership.) Jurisdiction to adjudicate each investor’s
partnership-related deficiencies on an individual basis was,
therefore, lacking, as dictated by the so-called TEFRA unified
audit and litigation procedures, set forth in sections 6221
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