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receipt by either the tax matters partner or a notice partner.
See, e.g., Crowell v. Commissioner, 102 T.C. 683, 692 (1994).
Respondent mailed the FPAAs to addressees at three
different addresses. We must now determine whether any of the
mailings was sufficient to meet the notice requirement of
section 6223(a).
A. Stone Canyon
The Stone Canyon address is the address listed on the 1999
Form 1065 return for SCP, JCB, and Investors. Unless respondent
was duly informed of a new address, sending the FPAA to the
Stone Canyon address addressed to the “Tax Matters Partner” was
appropriate pursuant to section 6223(a) and (c). Chomp
Associates v. Commissioner, 91 T.C. 1069, 1073-1074 (1988). The
address of John and Judith Bedrosian was not listed on the Form
1065 or the Schedule K-1 attached to the Form 1065.
SCP never updated in the prescribed manner the address that
was on the partnership return for 1999. As discussed supra,
section 301.6223(c)-1T(b)(1) and (3), Temporary Proced. & Admin.
Regs., supra, provides the procedure for furnishing respondent
with additional information. Petitioner argues that respondent
mailed numerous items to Rocco and therefore was aware of the
address. The mailing of correspondence does not alter
respondent’s obligations relating to the mailing of the FPAA.
Triangle Investors Ltd. Pship. v. Commissioner, supra at 616.
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