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under section 6223(b). Alternatively, SGE argues that the same
documents provided additional information which enabled
respondent to determine that the FPAA should have been sent to
Mr. Cobb directly. We disagree with both of SGE’s assertions.
As relevant herein, section 6223(b)(2) allows a group of
partners having an aggregate of 5 percent or more interest in
profits of the partnership to request notice of the FPAA. A
member of the group of partners must be designated as the one to
receive notice, and such information must be provided to the
Secretary 30 days prior to the mailing of the FPAA. Sec.
6223(b)(2) and (a) (flush language). As specifically stated in
the temporary regulations, the request for notice of a 5-percent
notice group must include the following information: (1)
Identity of the partnership by name, address, and taxpayer
identification number; (2) specific taxable year for which the
notice group is formed; (3) a designated member of the group to
receive the notices; (4) the name, address, taxpayer
identification number, and profits interest of each member of the
group; and (5) signatures of all partners comprising the notice
group. Sec. 301.6223(b)-1T, Temporary Proced. & Admin. Regs., 52
Fed. Reg. 6783 (Mar. 5, 1987), as amended in 52 Fed. Reg. 9296-01
(Mar. 24, 1987), and 61 Fed. Reg. 37683 (July 19, 1996).
SGE’s reliance on the authorization signed by Mr. Hoyt is
without merit. The authorization lacked the necessary
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