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its related partnerships.3 In March of 1989, in connection with
respondent’s criminal investigation into AMCOR’s operations and
pursuant to a search warrant, respondent entered an AMCOR office
and seized materials relating to the operation of AMCOR’s tax
shelter partnerships. Respondent did not return the materials he
seized from the search until 1993.
The United States never brought criminal charges against
AMCOR or its related partnerships. However, between 1990 and
1991, respondent issued separate notices of final partnership
administrative adjustment (FPAAs) to the tax matters partners
(TMPs) of several AMCOR partnerships including those partnerships
in which petitioner invested. Respondent determined that the
AMCOR partnerships had claimed several deductions to which they
were not entitled, resulting in millions of dollars of tax
adjustments.
The TMPs of several AMCOR partnerships, including the
partnerships in which petitioner invested, petitioned this Court
for review of the adjustments made in the FPAAs. Those cases
were litigated together, and decisions in the cases were entered
on July 19, 2001. Those decisions became final on or about
October 17, 2001. The decisions that pertain to the AMCOR
partnerships in which petitioner invested include, inter alia,
3 For some of the history of AMCOR and the investigation
into its operations, see, for example, Crop Associates-1986 v.
Commissioner, T.C. Memo. 2000-216.
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