Eliane Olson - Page 9

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               Validity of the Affected Items Notice of Deficiency                    
               Section 6223(a) generally requires that the Commissioner               
          mail each partner, whose name and address is furnished to the               
          Commissioner, notice of:  (1) The beginning of an administrative            
          partnership proceeding, and (2) the final partnership                       
          administrative adjustment resulting from that proceeding.  To               
          comply with section 6223(a), the Commissioner is required to use            
          the names, addresses, and profits interests of the partners shown           
          on the partnership return for the taxable year in issue, as                 
          modified by any additional information supplied in accordance               
          with applicable regulations.  Sec. 6223(c); Triangle Investors              
          Ltd. Partnership v. Commissioner, 95 T.C. 610, 613 (1990); sec.             
          301.6223(c)-1T(f), Temporary Proced. & Admin. Regs., 52 Fed. Reg.           
          6784 (Mar. 5, 1987).                                                        
               Supplementing the general provisions in section 6223(a),               
          section 301.6231(a)(2)-1T(a)(3), Temporary Proced. & Admin.                 
          Regs., 52 Fed. Reg. 6790 (Mar. 5, 1987), provides that "a spouse            
          who files a joint return with an individual holding a separate              
          interest in [a] partnership shall be treated as receiving any               
          notice received by the individual holding the separate interest."           
          This rule of constructive notice does not apply, however, if the            
          spouse without a separate partnership interest is identified on             
          the partnership return or has furnished information to the                  
          Commissioner with respect to his or her indirect interest in the            





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