- 7 - Discussion We decide whether the FPAA sent to petitioner met the notice requirement of section 6223(a). Petitioner argues it did not because CM Trust, rather than petitioner, was the partner of Ovation and respondent did not mail an FPAA to CM Trust. Respondent asserts that he had sufficient information identifying petitioner as an indirect partner of Ovation and establishing petitioner’s mailing address and indirect profits interest in Ovation. Respondent argues section 6223(c)(3) thus required respondent to mail the FPAA directly to petitioner, rather than to CM Trust. We agree with respondent. Section 6223(a) provides that the Commissioner must notify certain partners of the beginning and end of a partnership audit. With respect to an “indirect partner” owning an interest in the partnership through a “pass-thru partner” who would otherwise be entitled to notice, the Commissioner must give notice to the indirect partner, in lieu of the pass-thru partner, if the Commissioner is properly furnished with information as to the indirect partner’s name, address, and indirect profits interest in the partnership. See sec. 6223(c)(3); see also sec. 6231(a)(9) (defining a “pass-through partner” as “a partnership, estate, trust, S corporation, nominee, or other similar person through whom other persons hold an interest in the partnership”); sec. 6231(a)(10) (defining an “indirect partner” as a “personPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007