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in Sixty-Three Strategic Inv. Funds v. United States, at Case No.
3:05-cv-01123-VRW, in the U.S. District Court for the Northern
District of California, San Francisco, on March 17, 2005
(District Court case). Petitioner, on behalf of Voltaire, filed
a petition with respect to the FPAA in the Tax Court on May 13,
2005, titled Alverstone Strategic Inv. Fund, L.L.C., Voltaire
L.L.C., A Partner Other Than the Tax Matters Partner v.
Commissioner (docket No. 8753-05).
The Government filed a motion to dismiss for lack of
jurisdiction in the District Court case. Presidio filed a notice
of election to intervene and a motion to dismiss for lack of
jurisdiction in the Tax Court case at docket No. 8753-05 on
January 17, 2006. The District Court case has been stayed until
at least January 16, 2007, because of the pendency of a criminal
tax case in the District Court for the Southern District of New
York involving certain principals of Presidio. The Tax Court
case at docket No. 8753-05 has been held in abeyance pending
resolution of the related District Court litigation.
A statutory notice of deficiency with respect to his 1999
tax year was sent to petitioner on June 27, 2005. Respondent
determined a deficiency of $1,714,353 for that year. In the
notice of deficiency, respondent made adjustments to petitioner’s
income as follows:
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