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notice of final partnership administrative adjustment (FPAA).1
Further, respondent moved to dismiss for lack of jurisdiction on
the grounds that the petition is untimely. See generally
Kligfeld Holdings v. Commissioner, 128 T.C. 192 (2007), and
Notice 2000-44, 2000-2 C.B. 255, for a general description of the
transaction in this case.2
The issue for decision is whether respondent’s mailing of
the FPAA met the notice requirement of section 6223(a).
Background
Stone Canyon Partners (SCP) is a partnership, and
petitioner JCB Stone Canyon Investments, LLC (JCB), is a limited
liability company with John Bedrosian and Judith Bedrosian (the
Bedrosians) the sole members, holding their interest in JCB as
community property.3 JCB is the tax matters partner (TMP) of
SCP.
1 Unless otherwise indicated, all Rule references are to
the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
year in issue.
2 This case involves the same or related parties as in
docket Nos. 12341-05 and 24581-06. Docket No. 12341-05 is based
on a statutory notice of deficiency sent to John and Judith
Bedrosian. Docket No. 24581-06 is based on an affected items
notice sent to John and Judith Bedrosian.
3 The validity of the partnership is a matter of dispute
between the parties. The use of terms in this opinion, for
purposes of the pending motion, does not express any view on the
validity of any of the entities mentioned. Soward v.
Commissioner, T.C. Memo. 2006-262.
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