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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.
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Last modified: November 10, 2007