- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007