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partnership. Sec. 301.6231(a)(2)-1T(a)(3)(ii)(A) and (B),
Temporary Proced. & Admin. Regs.; sec. 301.6223(c)-1T(b), Proced.
& Admin. Regs., 52 Fed. Reg. 6790 (Mar. 5, 1987).
Petitioner contends that she was deprived of notice that the
partnership action had been commenced because she was living at
the Newton Street address on the date that the FPAA was mailed to
Mr. Olson at the Irish Lane address. Further, petitioner claims
that she and Mr. Olson had a very strained relationship and that
he did not inform her that he had received the FPAA.
We think that it is clear from our findings of fact that
respondent properly notified petitioner of the Computer Graphics'
partnership proceeding for the 1982 taxable year. Petitioner is
treated as though she was a partner in Computer Graphics because
she filed a joint return with Mr. Olson, who held a separate
interest in Computer Graphics for 1982. Therefore, under the
circumstances herein, any notice of the partnership proceeding
that was properly provided to Mr. Olson is deemed to have been
properly provided to petitioner. Sec. 301.6231(a)(2)-
1T(a)(3)(i), Temporary Proced. & Admin. Regs. Respondent
properly notified Mr. Olson of the partnership proceeding by
mailing a copy of the FPAA to Mr. Olson at his current address as
of April 18, 1988; i.e., the Irish Lane address.
If Mr. Olson did not inform petitioner of the partnership
proceeding, it is unfortunate. But, as much as we may sympathize
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