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of both the beginning and the end of administrative proceedings
at the partnership level. Sec. 6223(a). The ending notice is
the issuance of an FPAA. Sec. 6223(a)(2). A partner may then
seek judicial review of an FPAA by filing a petition for
readjustment of the partnership items with this Court. Sec.
6226.
The procedures under TEFRA parallel deficiency procedures in
that the notice--the FPAA--gives the taxpayer the right to
petition the Tax Court. Thus, we analyze the effect of errors in
an FPAA in the same way we analyze errors contained in a notice
of deficiency. See Sealy Power, Ltd. v. Commissioner, 46 F.3d
382, 386 (5th Cir. 1995), affg. in part and revg. in part on
another ground T.C. Memo. 1992-168.
The Commissioner is without authority to issue a notice of
deficiency for the wrong taxable year or for a period less than a
taxpayer’s full taxable year. For instance in Century Data Sys.,
Inc. v. Commissioner, 80 T.C. 529 (1983), the Commissioner used
fiscal years instead of the appropriate calendar years to
calculate the deficiency. See also Atlas Oil & Ref. Corp. v.
Commissioner, 17 T.C. 733 (1951); Columbia River Orchards, Inc.
v. Commissioner, 15 T.C. 253 (1950). We held the notice of
deficiency to be invalid because the adjustments “necessarily
omitted items of income and deduction of the correct taxable year
and * * * [or had] included other items which properly belong in
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