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than 1 percent. Therefore, SGE’s only recourse is to belong to a
notice group. As noted above, SGE did not satisfy the statutory
or regulatory requirements and does not belong to a notice group.
SGE further alleges that Daniel Smith, who, according to the
Schedule K-1 of the 1994 partnership return was a 6-percent
profit, loss, and ownership holder of Ranch Properties, was a
notice partner. Sec. 6223(b). Mr. Smith is not a party to this
action before us, and we find SGE’s argument irrelevant as to the
matter at hand. Whether or not Mr. Smith was afforded proper
notice of the FPAA in issue has no bearing on SGE’s objection to
respondent’s motion to dismiss for lack of jurisdiction.
Petitioner also argues that the FPAA notice mailed to the
Orovada address was never received by Gary Blackburn, a partner
of SGE who is authorized to receive mail at the Orovada address;
therefore, the FPAA is invalid. The record shows that the FPAA
notice was mailed to the Orovada address by certified mail on
August 13, 1998, received on August 15, 1998, and subsequently
forwarded to “Hoyt & Sons Fwd Portland OR 97204" on August 17,
1998. Based upon this evidence we find that respondent properly
notified the appropriate party, i.e., the designated TMP, at the
addresses provided by the partnership on its partnership return.
See sec. 6223(a), (b), and (c). Respondent mailed the FPAA to
the two addresses shown on Ranch Properties’ 1994 return in a
good faith effort to notify the partners of Ranch Properties of
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