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failed to comply with Rule 143(f).) Petitioner also argues that,
because respondent issued a FPAA to Spencer Medical Associates
II, a partnership with the same tax matters partner as Spencer
Medical, concerning adjustments related to a 1985 Coral
investment, respondent had knowledge of Spencer Medical.
In all of the cited cases dealing with the duty of
consistency and specifically addressing whether the Commissioner
had actual or constructive knowledge of the erroneously reported
item, the focus was on information supplied by the taxpayer on
the return for the year of the erroneous reporting or otherwise
developed upon audit of that return. In Mayfair Minerals, Inc.,
moreover, the Court rejected the taxpayer's contention that
reporting of the transaction on a return for a subsequent year,
filed by the same taxpayer, gave notice to the Commissioner of
the relevant facts in time to disallow the deductions for earlier
years. The Court stated that "this argument borders on the
facetious." Mayfair Minerals, Inc. v. Commissioner, supra at 91.
Petitioner seeks to equate information fortuitously
discovered during the investigation of another person with
information provided by the taxpayer on the return or during an
audit of the return on which the item was erroneously reported.
Petitioner's position supposes that the agent assisting the
Department of Justice in an investigation of Campbell should have
turned immediately to tracking down Spencer Medical upon receipt
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