129 T.C. No. 10
UNITED STATES TAX COURT
COLIN P. MURPHY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 656-06. Filed September 26, 2007.
P, an individual, is the sole beneficiary of an
irrevocable trust (T) which owns a 13-percent interest
in a general partnership (O). With respect to O’s 2000
taxable year, R mailed a notice of a final partnership
administrative adjustment (FPAA) to P, rather than to
T, for the purpose of meeting the notice requirement of
sec. 6223(a), I.R.C. When the FPAA was mailed, R
possessed readily available information relating to the
2000 Federal tax returns of P, T, and O. Those returns
reported P’s name, address, and indirect (through T)
profits interest in O.
Held: Pursuant to sec. 6223(c)(3), I.R.C., and
sec. 301.6223(c)-1T(f), Temporary Proced. & Admin.
Regs., 52 Fed. Reg. 6784 (Mar. 5, 1987), R’s mailing of
the FPAA to P, readily identified in R’s records as an
“indirect partner” of O within the meaning of sec.
6231(a)(10), I.R.C., met the notice requirement of sec.
6223(a), I.R.C.
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Last modified: November 10, 2007