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to the extent that petitioner requested a redetermination of
respondent’s adjustments to Ovation’s partnership items and of
respondent’s determination on the applicability of section 6662.2
As stipulated by the parties, the sole issue remaining for
decision is whether the FPAA sent to petitioner for Ovation’s
2000 taxable year met the notice requirement of section 6223(a).3
If the notice requirement was met, then petitioner concedes
liability for the deficiency determined in the affected items
notice of deficiency. We hold that the notice requirement was
met.
Background
All facts were stipulated or contained in the exhibits
submitted with the parties’ stipulation of facts. Those
stipulated facts and exhibits are incorporated herein by this
reference. Petitioner was born on October 16, 1985, and he
resided at 4 Carlisle Drive, Oak Brook, Illinois (Oak Brook
address), at all relevant times. His father, Kevin Murphy, also
resided at the Oak Brook address during those times.
On March 16, 1995, petitioner’s uncle (Michael Murphy),
petitioner’s accountant (Lester Detterback), and Kevin Murphy
formed the Collin Murphy Trust (CM Trust) for the sole benefit of
2 The Court also ordered stricken the paragraphs of the
petition that related to the same.
3 Petitioner raised this issue in an amended petition filed
with the Court on Nov. 30, 2006.
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Last modified: November 10, 2007