- 3 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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