ACM Partnership v. Commissioner IRS (Part II)

OPINION OF THE COURT

GREENBERG, Circuit Judge.

I. INTRODUCTION

Appellant ACM Partnership (“ACM”), through its tax matters partner Southampton-Hamilton Company (“Southampton”), appeals from a decision of the United States Tax Court dated June 12, 1997. The Tax Court’s jurisdiction rested on I.R.C. §§ 7442, 6213 and 6226 based on appellant’s timely filing of a petition seeking redetermination of a deficiency and review of a Final Partnership Administrative Adjustment. Appellate jurisdiction rests on I.R.C. § 7482(a)(1). Venue is proper pursuant to I.R.C. § 7482(b)(1)(A) as Southampton maintained…