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partnership's principal place of business is located, or
in the Court of Federal Claims. Sec. 6226(a). If the tax
matters partner fails to do so, any notice partner who has
an interest in the outcome has 60 additional days in which
to file such a petition. Sec. 6226(b)(1). If the petition
for readjustment is not filed by the tax matters partner
within 90 days or by a notice partner within 60 days after
the expiration of the 90-day period, as required by section
6226, then this Court lacks jurisdiction to readjust any of
the adjustments determined by respondent in the notice of
FPAA, and the petition must be dismissed. E.g., Triangle
Investors Ltd. Partnership v. Commissioner, 95 T.C. 610
(1990); Genesis Oil & Gas, Ltd. v. Commissioner, 93 T.C.
562, 563-566 (1989).
In the event that a court lacks jurisdiction to
consider a petition for readjustment because it was filed
by the tax matters partner beyond the filing deadline of
section 6226(a), then the court also lacks jurisdiction to
consider whether the notice of FPAA was issued beyond the
period of limitations for making assessments, set forth in
section 6229(a). Genesis Oil & Gas Ltd. v. Commissioner,
supra at 564. This is true because the issuance of a
notice of FPAA beyond the period of limitations does not
affect its validity. Id. Rather, the untimeliness of the
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