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On or about October 16, 2000, SCP filed a Form 1065, U.S.
Partnership Return of Income for 1999, listing 875 Stone Canyon
Road, Los Angeles, California 90077-2911 (Stone Canyon) as its
address. In addition, on the 1999 Form 1065, the addresses of
SCP’s two partners, JCB as TMP and Stone Canyon Investors, Inc.
(Investors), an S corporation wholly owned by John and Judith
Bedrosian as community property, were also listed as the Stone
Canyon address. The address of John and Judith Bedrosian is not
listed on the Form 1065 or the Schedule K-1, Partner’s Share of
Income, Credits, Deductions, etc. (Schedule K-1), attached to
the Form 1065.
On February 2, 2005, respondent mailed a notice of
beginning of administrative proceeding (NBAP) to commence a
partnership audit of SCP to John C. Bedrosian at 10550 Rocco
Drive, Los Angeles, California 90077-2904 (Rocco).4
During 2004 and 2005 respondent mailed various items to Mr.
Bedrosian at the Rocco address. On August 13, 2004, the
Bedrosians filed a Form 2688, Application for Additional
Extension of Time To File U.S. Individual Income Tax Return, for
2003 listing the Rocco address.
4 The proper address is 10550 Rocca Place, not Rocco Drive.
When informed of this address, respondent apparently transcribed
it incorrectly. Mail addressed Rocco Drive instead of Rocca
Place is still deliverable. Throughout this opinion, we use
Rocco.
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Last modified: March 27, 2008