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such a generic notice of FPAA was suggested by Congress
during its consideration of the partnership audit and
litigation provisions in precisely the situation presented
in this case; that is, where "the identity of the TMP may
not be known to the Secretary". H. Conf. Rept. 97-760, at
601 (1982), 1982-2 C.B. 600, 663. The use of a generic
notice of FPAA is authorized by the temporary regulations
promulgated under section 6223, section 301.6223(a)-1T(a),
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6783
(Mar. 5, 1987), and has been approved by this Court.
Triangle Investors Ltd. Partnership v. Commissioner, 95
T.C. at 614; Chomp Associates v. Commissioner, 91 T.C. at
1072-1073; Barbados #7 Ltd. v. Commissioner, 92 T.C. 804,
807-808 (1989); Seneca, Ltd. v. Commissioner, 92 T.C. 363
(1989). Based upon the generic notice of FPAA, we find
that respondent mailed the notice of FPAA to the tax
matters partner on January 28, 1991. It is unnecessary for
us to resolve the dispute over the identity of the tax
matters partner in order to find that the notice of FPAA
was mailed to the tax matters partner. Cf. Seneca, Ltd. v.
Commissioner, supra.
Both the stipulation of facts and the Rule 122
stipulation state that the generic notice of FPAA was
mailed by respondent on January 28, 1991. We find nothing
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