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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.
Background
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
existed.
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Last modified: November 10, 2007