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FPAA is issued. Genesis Oil & Gas, Ltd. v. Commissioner,
supra.
In order to be valid, a notice of FPAA must provide
adequate or minimal notice that the Commissioner has
finally determined adjustments to the partnership return.
Triangle Investors Ltd. Partnership v. Commissioner, supra
at 613; Chomp Associates v. Commissioner, 91 T.C. 1069,
1073-1075 (1988); Clovis I v. Commissioner, 88 T.C. 980,
982 (1987). The validity of a notice of FPAA that has been
properly mailed is not contingent upon actual receipt by
either the tax matters partner or a notice partner.
Crowell v. Commissioner, supra at 692; cf. Yusko v.
Commissioner, 89 T.C. 806, 810 (1987).
The parties to this case contend that the subject
petition for readjustment must be dismissed by the Court
for lack of jurisdiction. Respondent's motion to dismiss
is based upon the fact that the petition for readjustment
was filed by partners other than the tax matters partner
more than 150 days after the date on which the notice of
FPAA was issued to the tax matters partner, and, thus,
was filed beyond the jurisdictional time limit for such a
petition, as set forth in section 6226(b)(1). Respondent
does not seek dismissal of the instant petition on the
ground that petitioners do not have an interest in the
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