- 4 - distributive share of long-term capital loss from Investors of $17,250,088 for 1999. On April 8, 2005, respondent issued a notice of final partnership administrative adjustment (FPAA) to the partners of Stone Canyon for 1999. Eleven days after the FPAA was issued, respondent issued petitioners a statutory notice of deficiency for 1999 and 2000. Petitioners timely petitioned the Court to review the notice of deficiency. Discussion I. Respondent’s Motion To Dismiss The Tax Court is a court of limited jurisdiction, and we may exercise our jurisdiction only to the extent provided by Congress. See sec. 7442; see also GAF Corp. & Subs. v. Commissioner, 114 T.C. 519, 521 (2000). We have jurisdiction to redetermine a deficiency if a valid notice of deficiency is issued by the Commissioner and if a timely petition is filed by the taxpayer. GAF Corp. & Subs. v. Commissioner, supra at 521. The partnership-level proceeding described in sections 6221 through 6234 requires that all challenges to adjustments of partnership items contained in the FPAA are to be made in a single unified proceeding. Under these procedures, the tax treatment of any partnership item shall be determined at the partnership level. Sec. 6221.Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: March 27, 2008