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Intermountain Ins. Serv. of Vail, LLC v. Comm'r, 2010 U.S. Tax Ct. LEXIS 14 (T.C. May 6, 2010)

The Tax Court, in a division opinion, denied motions to reconsider and vacate its prior decision that held that a final partnership administrative adjustment was untimely because a basis overstatement didn't trigger the six-year statute of limitations and has rejected the retroactive application...