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notice of deficiency that included adjustments relating to
partnership items.
In response to the FPAAs, Jimmy C. Chisum, on July 17, 2000,
initiated a single partnership-level proceeding, Stephens City
Chiropractic, PLC v. Commissioner, docket No. 7982-00. On April
2, 2001, this Court dismissed the partnership-level proceeding
for lack of jurisdiction on the ground that Mr. Chisum failed to
establish his capacity to act on behalf of the entities.3 On
July 1, 2001, the decision in the partnership-level proceeding
became final.
In response to the notice of deficiency, petitioner, on July
14, 2000, initiated a partner-level proceeding, Hudspath v.
Commissioner, docket No. 7901-00. On December 7, 2001, this
Court granted respondent’s motion to dismiss for lack of
jurisdiction and to strike the portion of the partner-level
proceeding relating to partnership items on the ground that
respondent had sent petitioner, pursuant to section 6225, a
notice of deficiency prior to the completion of the partnership-
level proceeding.
3 Mr. Chisum has initiated several proceedings that this
Court has dismissed on similar grounds. E.g., Universal Trust
06-15-90 v. Commissioner, T.C. Memo. 2000-390; Banana Moon Trust
v. Commissioner, T.C. Memo. 2000-73; Jeff Burger Prods., LLC v.
Commissioner, T.C. Memo. 2000-72.
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