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(Burns address). In prior tax years of Ranch Properties, not at
issue before us, some of the partners of Ranch Properties,
including Shorthorn Genetic Engineering 1984-5 (SGE), J.V.,
received FPAA notices from respondent. However, no other FPAA
notices were issued or mailed to any partner of Ranch Properties
other than the tax matters partner (TMP) for tax year 1994.
The 90-day period within which the TMP could file a petition
for redetermination of partnership adjustments with this Court
expired on November 11, 1998. Sec. 6226(a). The subsequent 60-
day period within which a partner other than the TMP could file a
petition for redetermination of partnership adjustments expired
on January 11, 1999. Sec. 6226(b). SGE is a partnership and
pass-through-partner of Ranch Properties. SGE, through its
attorney, Montgomery Cobb (Mr. Cobb), filed a petition for
readjustment of partnership items as a partner other than the TMP
on December 7, 2000. According to the Schedule K-1, Partner’s
Share of Income, Credits, Deductions, Etc., attached to the 1994
partnership return, SGE was a 0.65-percent profit, loss, and
ownership holder of Ranch Properties. In the FPAA notice
respondent determined that the distributive share and allocation
for each of the 116 partners of Ranch Properties was 0.862
percent.
The 1994 U.S. Partnership Return of Income (1994 return),
Form 1065, on which this case is based, was prepared by Walter J.
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