- 2 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011