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partnership loss of $810 from Utah Jojoba I. In a partnership
proceeding, Utah Jojoba I Research v. Commissioner, T.C. Memo.
1998-6, the Court determined that the partnership’s claimed loss
deductions for 1982 and 1983 were not allowable. The resultant
adjustments to petitioners’ 1982 and 1983 Federal income taxes
resulted in deficiencies of $9,286 and $162, respectively. See
sec. 6225.
Validity of Notice of Deficiency.
Petitioners contend that they were unaware that the Utah
Jojoba I partnership was being audited and that there was
litigation in the Tax Court. Petitioners claim that they
received no correspondence from the Commissioner or from the tax
matters partner until they were notified of the computational
adjustment resulting from the partnership level proceeding.
While it is not clear, it appears that petitioners are claiming
that the notice of deficiency for the affected items is invalid.
Petitioners contend that if they had been notified about the
audit and litigation, they would have “taken care of the matter
at an earlier date” instead of having to deal currently with the
additions to tax and accrued interest.
Petitioners rely on a letter found in respondent’s file.
The letter was prepared by the Internal Revenue Service (IRS) and
addressed to 13723 Walnut Street, Whittier, CA (the Walnut Street
address). A copy of an envelope attached to the letter bears a
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