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Zealand, petitioner received a telephone call from an employee of
the Houston District examination division. The employee notified
petitioner that respondent was examining his 1982 Form 1040.
Petitioner knew at that time that respondent was also examining
the partnership items of Elite reflected on his 1982 Form 1040,
in an administrative proceeding that had been ongoing for at
least the prior 10 months. Petitioner was notified in
approximately February 1986 about the commencement of that
proceeding. On February 6, 1986, Elite's tax matters partner
executed an extension agreement extending the period of
limitation with respect to Elite's 1982 taxable year.
In August 1987, petitioner received a letter from the
Houston District examination division advising him that
respondent's examination of his 1982 Form 1040 was discontinued.
The letter did not mention Elite’s partnership examination.
On March 7, 1988, respondent sent to petitioner three
notices of final partnership administrative adjustment (FPAA’s)
pertaining to Elite's 1982, 1983, and 1984 taxable years. Each
of the FPAA’s was sent in a separate envelope bearing the forms
and postage for certified mail to petitioner's address in New
Zealand. Petitioner received the 1983 and 1984 FPAA’s.
Petitioner did not receive the 1982 FPAA. The adjustments
contained in the 1983 and 1984 FPAA’s did not generate any
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