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procedures to issue a notice of FPAA to the tax matters
partner and the notice partners. See generally 1 Audit,
Internal Revenue Manual (CCH), sec. 4227.47, at 7233-20.
In the notice of FPAA prepared by Mr. Norstrud, respondent
determined that in computing the amount of property
eligible for investment credit for 1983, the partnership is
not entitled to take into account, as qualifying section 38
property, the alleged basis of the partnership in a video
disk in the amount of $8,436,271. Mr. Norstrud transmitted
the FPAA package to the Austin Compliance Center in Austin,
Texas, for processing and mailing of the notice of FPAA to
the tax matters partner and notice partners.
On January 28, 1991, respondent mailed duplicate
original notices of FPAA that are the subject of this
proceeding. One of the notices of FPAA was addressed to
"Wayne H. Caldwell, Wayne H. Caldwell, Escrow". A second
notice of FPAA was addressed to "Tax Matters Partner c/o
Wayne H. Caldwell Escrow." Both notices were sent to "5952
Royal Lane #117, Dallas, Texas, 75230". This is the street
address that was used on the partnership's 1983 returns and
is the address of Mr. Caldwell's business. In this
opinion, we refer to the second notice of FPAA as the
generic notice of FPAA.
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