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apply with respect to all taxable years of a partnership
beginning after September 3, 1982. Sparks v. Commissioner, 87
T.C. 1279, 1284 (1986). The TEFRA procedures apply to the
taxable year 1994 of Ranch Properties.
This Court has previously held that the standard for
determining the validity of an FPAA is whether the FPAA provides
adequate or minimal notice to the taxpayer of the Commissioner’s
final determination of adjustments to the partnership return.
Triangle Investors Ltd. Pship. v. Commissioner, 95 T.C. 610, 613
(1990); Chomp Associates v. Commissioner, 91 T.C. 1069, 1073-1074
(1988); Byrd Inv. v. Commissioner, 89 T.C. 1, 6-7 (1987), affd.
without published opinion 853 F.2d 928 (11th Cir. 1988).
Furthermore, the validity of an FPAA is not contingent upon
actual receipt by the TMP or a notice partner. Crowell v.
Commissioner, 102 T.C. 683, 692 (1994); see also Seneca Ltd. v.
Comissioner, 92 T.C. 363, 368 (1989), affd. without published
opinion 899 F.2d 1225 (9th Cir. 1990).
In the motion to dismiss, respondent contends that the Court
does not have jurisdiction to redetermine any items in the FPAA
because the petition was not filed within the period specified in
section 6226(a) or (b), and on the grounds that SGE is not a
notice partner.
SGE argues that the Cobb letter, combined with the
authorization by Mr. Hoyt, serves as the notice group request
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