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Commissioner, 95 T.C. 610, 613 (1990). Section 6223(a)
generally provides that respondent shall mail to each partner
whose name and address is furnished to the Secretary an NBAP
with respect to a partnership item, as well as notice of the
FPAA resulting from any such proceeding. It is the mailing of
the FPAA that triggers the time periods for filing a petition
for readjustment of the partnership items by either the tax
matters partner or a notice partner under section 6226(a) and
(b).
For purposes of mailing the notices specified in section
6223(a), including an FPAA, respondent is required to use the
names, addresses, and profit interests of the partners shown on
the partnership return for the year at issue as modified by
additional information furnished to respondent by the TMP or any
other person in accordance with regulations prescribed by the
Secretary. Sec. 6223(c)(1) and (2). Further, section
301.6223(c)-1T, Temporary Proced. & Admin. Regs., 52 Fed. Reg.
6784 (Mar. 5, 1987), provides in pertinent part:
(a) In general. In addition to the names, addresses,
and profits interests as shown on the partnership return,
the Service will use additional information as provided in
this section for purposes of administering subchapter C of
chapter 63 of the Code.
(b) Procedure for furnishing additional information--
(1) In general. Any person may furnish additional
information at any time by filing a written statement with
the Service. However, the information contained in the
statement will be considered for purposes of determining
whether a partner is entitled to a notice described in
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