- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008