Meserve Drilling Partners, Regional Resources, Inc., F.K.A. R&R Energy, Inc., Tax Matters Partner - Page 4

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          Naftel v. Commissioner, 85 T.C. 527, 530 (1985); Estate of Young            
          v. Commissioner, 81 T.C. 879, 880-881 (1983).  Moreover, we have            
          jurisdiction to determine whether we have jurisdiction.  Pyo v.             
          Commissioner, 83 T.C. 626, 632 (1984); Kluger v. Commissioner, 83           
          T.C. 309, 314 (1984).                                                       
               In a partnership action for readjustment of partnership                
          items, this Court has jurisdiction when the Commissioner has                
          mailed a valid FPAA and the tax matters partner or other eligible           
          partner has timely filed a petition with the Court seeking a                
          readjustment of partnership items.  Sec. 6226; Rule 240(c).  If             
          the FPAA is not valid, we lack subject matter jurisdiction.                 
          Clovis I v. Commissioner, 88 T.C. 980 (1987); Maxwell v.                    
          Commissioner, 87 T.C. 783, 788-789 (1986).                                  
          At a minimum, the FPAA must give notice to the taxpayer that the            
          Commissioner has finally determined adjustments to the                      
          partnership return.  Chomp Associates v. Commissioner, 91 T.C.              
          1069, 1073-1074 (1988); Clovis I v. Commissioner, supra at 982.             
               Petitioner's argument as to jurisdiction turns on section              
          301.6231(a)(3)-1(a), Proced. & Admin. Regs, which defines                   
          "partnership items".  The unified audit and litigation procedures           
          applicable to partnership items, which are found in sections                
          6221-6233, were enacted as part of the Tax Equity and Fiscal                
          Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 401(a),            
          96 Stat. 648, and are effective for partnership taxable years               
          commencing after September 3, 1982.  The TEFRA partnership                  




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