- 3 - section 6223(c)(1), respondent mailed the NBAP to petitioner at the address set forth on Schedule K-1 of the partnership return. 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. The FPAA that was sent to petitioner was mailed to him at 1445 E. Irish Lane, Littleton, Colorado 80122 (the Irish Lane address). Petitioner resided at the Irish Lane address on April 18, 1988, and continued to reside there at least through September 26, 1995. 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, and it served to commence a partnership level proceeding (the partnership proceeding). In September 1992, respondent filed a motion to dismiss for failure to properly prosecute and a motion for appointment of tax matters partner in the partnership proceeding. Subsequently, inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011