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section 6223(a) only if the Service receives the statement
at least 30 days before the date on which the Service mails
the notice to the tax matters partner. Similarly,
information contained in the statement generally will not
be taken into account for other purposes by the Service
until 30 days after the statement is received.
* * * * * * *
(3) Contents of statement. The statement
shall–
(i) Identify the partnership, each partner
for whom information is supplied, and the person
supplying the information by name, address, and
taxpayer identification number;
(ii) Explain that the statement is
furnished to correct or supplement earlier
information with respect to the partners in the
partnership;
(iii) Specify the taxable year to which the
information relates;
(iv) Set out the corrected or additional
information, and
(v) Be signed by the person supplying the
information.
* * * * * * *
(f) Service may use other information. In
addition to the information on the partnership return
* * * the Service may use other information in its
possession (for example, a change in address reflected
on a partner’s return) in administering subchapter C
of chapter 63 of the Code. However, the Service is
not obligated to search its records for information
not expressly furnished under this section.
As is the case with a statutory notice of deficiency, the
validity of a properly mailed FPAA is not contingent upon actual
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Last modified: March 27, 2008