- 47 - permit an inference that the notice of FPAA was not mailed to the notice partners. We also reject petitioners' final point that the FPAA Certified Mail Listing is unreliable and should be excluded from evidence by reason of the fact that it records the mailing of 29 letters, whereas there were only 27 partners in the partnership. Petitioners fail to take note of the fact that the notice of FPAA was mailed to petitioners "Charles P. & Louetta J. Niven" at two different addresses, and that the notice of FPAA was also mailed to "Robert L. Jondele" at two different addresses. Petitioners' final contention is that, as a matter of law, the expiration of the period of limitations on assessment, prescribed by section 6229, prior to the mailing of the notice of FPAA, made it impossible for respondent to mail the notice of FPAA to notice partners within the time required by section 6223(d)(2). Petitioners contend that, as a result of the expiration of the period of limitations, all of the partnership items of the notice partners were automatically converted to nonpartnership items under the remedy provision of section 6223(e). In effect, petitioners contend that the period of limitations on assessment set forth in section 6229 isPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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