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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.
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