- 8 -
return nor claimed by petitioners as their distributive share of
any deduction on the partnership return. The disallowance of the
deduction at the individual level did not flow from a deduction
disallowed at the partnership level, nor is the legality of the
deduction at the individual level necessarily affected by a
determination at the partnership level. Id.
Respondent’s motion to dismiss for lack of jurisdiction will
be granted in part and denied in part.
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and, to the extent not
mentioned above, we find them to be irrelevant or without merit.
To reflect the foregoing,
An appropriate order will
be issued.
Page: Previous 1 2 3 4 5 6 7 8
Last modified: March 27, 2008