- 10 - resulting from the administrative proceeding at the partnership level. Energy Resources, Ltd. v. Commissioner, 91 T.C. 913, 916 (1988). Petitioners argue that the "defective" caption of the Lax case deprived them of notice that a partnership action had been commenced. There is no question that the Commissioner mailed the FPAA's to the TMP of MCDA II. It was the TMP who was statutorily required to provide notice to petitioners that a partnership action had been commenced. Sec. 6223(g). As explained by this Court, "The tax matters partner must also perform important functions within the partnership. He is required to keep all partners informed of the status of administrative and judicial proceedings involving the partnership." Computer Programs Lambda, Ltd. v. Commissioner, 89 T.C. 198, 205 (1987). Jurisdictionally, we do not find that the "defects" in the Lax petition played any role in the notice required in this affected items proceeding. Petitioners were to be notified of the partnership action by the TMP of MCDA II, not by the caption of the Lax petition. In any event, failure by the TMP to provide notice would not affect the applicability of the partnership proceedings. Sec. 6230(f). This Court has upheld the constitutionality of the TEFRA partnership procedures. Boyd v. Commissioner, 101 T.C. 365, 374 (1993). Respondent's mailing of the FPAA to the TMP of MCDA II satisfied all requirements and therefore did not deny petitioners due process.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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