Stone Canyon Partners, JCB Stone Canyon Investments, LLC, Tax Matters Partner - Page 2




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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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