- 8 - Under section 6226, the tax matters partner of a partnership may file a petition for a readjustment of the partnership items for such taxable year with the Tax Court, the District Court of the United States for the district in which the partnership’s principal place of business is located, or the Claims Court (now Court of Federal Claims), within 90 days after the day on which a notice of an FPAA is mailed to the tax matters partner. Sec. 6226(a). If the tax matters partner does not file a readjustment petition under subsection (a) of section 6226 with respect to any FPAA, any notice partner may, within 60 days after the close of the 90-day period set forth in subsection (a), file a petition for a readjustment of the partnership items for the taxable years involved with any of the courts described in subsection (a). Sec. 6226(b). The 90-day period for the tax matters partner to file a petition in regard to the FPAA issued on December 17, 2004, expired on March 17, 2005. The 60-day period for the notice partner to file a petition in regard to the FPAA issued on December 17, 2004, expired on May 16, 2005. The dates of the petitions relating to the FPAA fall within the required periods in which a tax matters partner or a notice partner would need to file. Sec. 6226(a) and (b). However, the unresolved jurisdictional issues in those partnership cases are not determinative of the jurisdictional issue presented in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011