Petaluma FX Partners, LLC, Ronald Scott Vanderbeek, A Partner Other Than The Tax Matters Partner - Page 4

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          erroneous August 31, 2000, taxable year contained in his answer             
          was itself an error.  Respondent suggests that the revenue agent            
          who issued the original FPAA did so with the intent of making               
          adjustments for Petaluma’s taxable year ending August 31, 2000.             
          According to respondent, the revenue agent was confused by                  
          Petaluma’s 2001 return which was filed for a short taxable year             
          ending August 31, 2001.                                                     
               Respondent moves to dismiss the petition for lack of                   
          jurisdiction.  Respondent argues that because the July 28, 2005,            
          notice makes adjustments for the wrong taxable year ending August           
          31, 2000, instead of the taxable year ending December 31, 2000,             
          the FPAA is invalid, and the Court lacks jurisdiction to review             
          the adjustments therein.  Respondent argues that the only FPAA              
          upon which the Court’s jurisdiction could have been invoked                 
          properly was the corrected FPAA issued on August 30, 2005.                  
               The Tax Court is a court of limited jurisdiction, and we may           
          exercise our jurisdiction only to the extent provided by                    
          Congress.  See sec. 7442; see also GAF Corp. & Subs. v.                     
          Commissioner, 114 T.C. 519, 521 (2000).  This Court’s                       
          jurisdiction with respect to the tax treatment of partnerships is           
          derived from the Tax Equity and Fiscal Responsibility Act of 1982           
          (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648.  Under the              
          TEFRA provisions, the Commissioner must give notice to partners             

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