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On March 23, 1988, and pursuant to section 6223(a)(2),
respondent mailed a notice of final partnership administrative
adjustment (FPAA) to Computer Graphics' tax matters partner (TMP)
regarding the partnership's 1982 taxable year. Approximately one
month later, on April 18, 1988, and pursuant to section
6223(a)(2) and (d)(2), respondent mailed a copy of the FPAA to
petitioner and Mr. Olson at Mr. Olson's Irish Lane address.
The copy of the FPAA that was sent to petitioner and Mr.
Olson was addressed to "Robert C. and Eliane Olson" because
petitioner and Mr. Olson had filed a joint Federal income tax
return for 1982. By virtue of section 6231(a)(2)(B), petitioner
is deemed to be a partner for purposes of the unified partnership
audit and litigation procedures.2
In August 1988, a petition for readjustment of partnership
items was filed in response to the FPAA that respondent had
previously issued in respect of Computer Graphics' 1982 taxable
year. The petition, which was assigned docket No. 21062-88, was
filed by a partner other than petitioner or Mr. Olson, and it
served to commence a partnership level proceeding (the
partnership proceeding).
2 Pursuant to sec. 6231(a)(2)(B), the term "partner"
includes not only a partner in the partnership, but "any other
person whose income tax liability * * * is determined in whole or
in part by taking into account directly or indirectly partnership
items of the partnership." By virtue of sec. 6013(d)(3), the
liability for income tax in respect of a joint return filed by a
husband and wife is joint and several.
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