AHG Investments, LLC, Alan Ginsburg, A Partner Other Than the Tax Matters Partner v. Commissioner

OPINION

Goeke, Judge:

This case is before the Court on petitioner’s motion for partial summary judgment filed pursuant to Rule 121, 1 to which respondent objects. Respondent issued a notice of final partnership administrative adjustment (FPAA) to petitioner, a partner other than the tax matters partner (TMP) of AHG Investments, LLC (AHG Investments). The major adjustment in the FPAA was to disallow $10,069,505 in losses allocated to petitioner for taxable years 2001 and 2002. Petitioner conceded on grounds other than valuation or basis that the FPAA adjustments were correct in an attempt to…