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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, in
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