John C. Bedrosian and Judith D. Bedrosian - Page 5




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               Pursuant to section 6226, the TMP of a partnership                     
          may file a petition for a readjustment of the partnership items             
          for a 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 Court of Federal             
          Claims, within 90 days after the day on which a notice of an FPAA           
          is mailed to the TMP.  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 Commissioner generally must wait until a partnership-              
          level proceeding is over to determine a liability attributable to           
          a partnership item.  See sec. 6225(a); Maxwell v. Commissioner,             
          87 T.C. 783, 788 (1986).  Section 6225(a) provides:                         
                    SEC. 6225(a).  RESTRICTION ON ASSESSMENT AND                      
               COLLECTION.--Except as otherwise provided in this                      
               subchapter, no assessment of a deficiency attributable to              
               any partnership item may be made (and no levy or proceeding            
               in any court for the collection of any such deficiency may             
               be made, begun, or prosecuted) before--                                
                         (1)  the close of the 150th day after the day on             
                    which a notice of a final partnership administrative              
                    adjustment was mailed to the tax matters partner, and             
                         (2)  if a proceeding is begun in the Tax Court               
                    under section 6226 during such 150-day period, the                







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