- 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 Next
Last modified: March 27, 2008