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Background
Petitioner resided in San Francisco, California, at the time
that he filed his petition.
A Notice of Final Partnership Administrative Adjustment
(FPAA) was issued by respondent for the tax year ended
November 22, 1999, with respect to Alverstone Strategic
Investment Fund, L.L.C. (Alverstone SIF), on December 17, 2004.
Because Alverstone SIF is a purported partnership with more than
10 partners and its first taxable year commenced after
September 3, 1982, it is subject to the unified audit and
litigation procedures of sections 6221-6234 (commonly known as
TEFRA). The validity of the partnership is a matter of dispute
between the parties. The use of terms in this opinion, for
purposes of the pending motion, does not express any view on the
validity of any of the entities mentioned. See Oceanic Leasing
v. Commissioner, T.C. Memo. 1996-458; see also sec. 6233; sec.
301.6233-1T, Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6795
(Mar. 5, 1987).
Voltaire L.L.C. (Voltaire) is a notice partner of Alverstone
SIF within the meaning of section 6231(a)(8) because Voltaire
held an interest in Alverstone SIF during 1999. Therefore, a
copy of the FPAA was sent to and received by Voltaire.
A petition was filed with respect to the FPAA by Presidio
Growth, L.L.C. (Presidio), tax matters partner of Alverstone SIF,
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Last modified: May 25, 2011