Petaluma FX Partners, LLC, Ronald Scott Vanderbeek, A Partner Other Than The Tax Matters Partner - Page 3

                                        - 3 -                                         
          relating to the purchase and transfer of offsetting options to              
          the partnership should be disregarded for tax purposes.  While              
          the adjustments respondent made in the FPAA pertain to the period           
          October 10 to December 31, 2000, respondent’s FPAA reflects that            
          the adjustments are being made for the taxable year ending August           
          31, 2000.                                                                   
               On August 30, 2005, respondent issued a corrected FPAA to              
          the tax matters partner and the notice partners of Petaluma to              
          reflect that the adjustments were made for the taxable year                 
          ending December 31, 2000.  With two exceptions, the adjustments             
          made in the August 30, 2005, FPAA were identical to the                     
          adjustments made in the July 28, 2005, FPAA.3                               
               On December 30, 2005, Ronald Scott Vanderbeek, as a notice             
          partner of Petaluma, filed a petition seeking review of the                 
          adjustments set forth in the FPAA dated July 28, 2005.  On May              
          10, 2006, respondent filed his answer.  In his answer, respondent           
          admitted that the date reflecting a taxable year ending August              
          31, 2000, contained in the initial FPAA was a typographical error           
          and that a corrected FPAA reflecting the proper taxable year                
          ending December 31, 2000, had been issued.  Respondent attached             
          the corrected FPAA to his answer.                                           
               Respondent now submits that the admission pertaining to the            

               3The corrected FPAA did not contain adjustments for: (1)               
          liabilities and capital-other current liabilities, and (2)                  
          partner’s capital accounts.                                                 

Page:  Previous  1  2  3  4  5  6  7  8  Next 

Last modified: November 10, 2007