Petaluma FX Partners, LLC, Ronald Scott Vanderbeek, A Partner Other Than The Tax Matters Partner - Page 2

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          Respondent argues that the Court lacks jurisdiction because the             
          notice of final partnership administrative adjustment (FPAA)                
          dated July 28, 2005, upon which the petition is based, was issued           
          for the taxable year of Petaluma FX Partners, LLC (Petaluma),               
          ending August 31, 2000, and thus does not confer jurisdiction on            
          this Court to review adjustments made to Petaluma’s taxable year            
          ending December 31, 2000.  Because we find the FPAA makes                   
          adjustments for the taxable year ending December 31, 2000, and              
          because any reference to the taxable year ending August 31, 2000,           
          was an error typographical in nature, respondent’s motion to                
          dismiss will be denied.                                                     
               Petaluma, a purported partnership,2 was formed in August               
          2000, and began its business activities on October 10, 2000.                
          Petaluma was a calendar year taxpayer and, on April 2, 2001,                
          filed its Form 1065, U.S. Return of Partnership Income, for the             
          taxable year ending December 31, 2000.                                      
               On July 28, 2005, respondent issued an FPAA to the tax                 
          matters partner and the notice partners of Petaluma.  Respondent            
          determined that the partnership as well as certain transactions             

               2Respondent contests whether a partnership existed as a                
          matter of fact.  We use the terms “partnership” and “partner” for           
          convenience and without deciding whether a partnership in fact              

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