Stone Canyon Partners, JCB Stone Canyon Investments, LLC, Tax Matters Partner - Page 4




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               On February 18, 2005, Linda Olson (Olson), a certified                 
          public accountant to whom the Bedrosians delegated a power of               
          attorney, sent Revenue Agent Deborah Smyth a letter informing               
          Agent Smyth of a change of address for SCP, JCB, and Investors.             
          Olson’s letter listed 270 North Canon Drive #1209, Beverly                  
          Hills, California 90210 (North Canon), a private mailbox, as the            
          new address.  Olson did not have power of attorney for any of               
          the entities, only for the Bedrosians as individuals.                       
               On April 5, 2005, 3 days before the mailing of the 14                  
          FPAAs, Olson notified Revenue Agent Smyth by telephone that the             
          Bedrosians’ mail could no longer be delivered to the North Canon            
          address and that 2934½ Beverly Glen Circle, #419, Los Angeles,              
          California 90077 (Beverly Glen) was the new private mailbox                 
          being used by the Bedrosians.  Olson notified Revenue Agent                 
          Smyth that the Bedrosians’ residence was still Rocco.  As a                 
          result of the telephone conversation, Revenue Agent Smyth                   
          prepared Forms 2363, Master File Entity Change, for SCP,                    
          Investors, and the Bedrosians listing the Beverly Glen address.             
          On April 8, 2005, respondent mailed 14 FPAAs regarding SCP                  
          to addressees at three different addresses:  (1) Stone Canyon,              
          (2) Beverly Glen, and (3) North Canon.  Petitioner did not file             
          a petition to contest the FPAA until May 1, 2007, more than 2               
          years after the FPAAs had been sent.  No petition to contest the            
          FPAAs had previously been filed by any partner.  The FPAAs were             







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