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Albert L. Grasso, Joseph A. Zarlengo, and David B. Shiner,
for petitioner.
John J. Boyle, for respondent.
OPINION
LARO, Judge: This case is a Son-of-BOSS case submitted to
the Court fully stipulated pursuant to Rule 122.1 See generally
Kligfeld Holdings v. Commissioner, 128 T.C. 192 (2007), and
Notice 2000-44, 2000-2 C.B. 255, for a general description of
Son-of-BOSS cases. Petitioner petitioned the Court on January 9,
2006, to redetermine respondent’s determination of a $444,063
deficiency in petitioner’s 2000 Federal income tax and a
$177,625.20 accuracy-related penalty under section 6662. The
determinations were contained in an affected items notice of
deficiency mailed to petitioner on October 11, 2005, relating to
respondent’s adjustments in a notice of final partnership
administrative adjustment (FPAA) issued for the 2000 taxable year
of a general partnership named Ovation Trading Partners
(Ovation).
In an order dated November 1, 2006, the Court granted
respondent’s motion to dismiss this case for lack of jurisdiction
1 Rule references are to the Tax Court Rules of Practice and
Procedure. Unless otherwise noted, section references are to the
applicable versions of the Internal Revenue Code.
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Last modified: November 10, 2007