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that it was impractical to use the general partner with the
largest profit interest whose name appears first in the alphabet
as TMP for 1983, nor did respondent make a selection of a TMP for
the partnership for 1983 after determining that it was
impractical to use the general partner with the largest profits
interest whose name appears first in the alphabet.
On August 24, 1987, respondent sent a 60-day letter to Mr.
Farley with respect to the partnership. Mr. Farley filed, as
authorized representative for the partnership, a written protest
in response to the 60-day letter. On October 11, 1988,
respondent issued a notice of final partnership administrative
adjustment (FPAA) to the partnership for the years 1983, 1984,
and 1985 (the 1988 FPAA). The 1988 FPAA was not addressed to a
specific individual, but rather was a generic FPAA issued to the
TMP for the partnership, at the address on the partnership's 1983
return. Respondent did not allege in the 1988 FPAA that any
proposed adjustment to the partnership's 1983 return was due to a
false return, fraud, or a gross omission from income.
The partnership, Richard E. Doyle and Nancy B. Doyle,2 and
petitioners, as partners other than the TMP, timely filed a
petition for readjustment of partnership items set forth in the
FPAA on February 21, 1989 (the 1989 petition), which was docketed
2 Richard and Nancy Doyle are Mr. Doyle's brother and
sister-in-law. Brown v. Commissioner, T.C. Memo. 1992-379, affd.
without published opinion sub nom. Konenkamp v. Commissioner, 14
F.3d 47 (3d Cir. 1993).
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