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in 1983 and 1984, and therefore was a notice partner. Sec.
6223(a) and (b).
The FPAA's determined adjustments to the partnership items
of MCDA II. A petition for readjustment of final partnership
administrative adjustments was not filed by the TMP of MCDA II
within 90 days. However, a petition for readjustment of final
partnership administrative adjustments was timely filed by Robert
and Wendy Lax on March 16, 1992, and was assigned docket No.
5757-92 (the Lax case). The caption of the Lax case read, in
pertinent part:
MidContinental Drilling Co.
Partnership,
Robert and Wendy Lax, Partners
Other Than The Tax Matters Partner
Petitioners,
Paragraph 2 of the petition stated "The Partnership's taxpayer
identification number is 13-3093089." Attached to the petition
were the two FPAA's issued to Robert and Wendy Lax concerning
MCDA II. In the FPAA for 1983, respondent refers to MCDA II as
"Mid-Continent Drilling Associates" and "Mid Continent Drilling
Associates II". In the FPAA for 1984, respondent refers to MCDA
II as "Mid-Continental Drilling Co." and "Mid Continent Drilling
Associates II". However, each of the above references is
followed by the EIN of 13-3093089, which is the EIN of MCDA II.
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