Stone Canyon Partners, JCB Stone Canyon Investments, LLC, Tax Matters Partner - Page 10




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          Petitioner never followed the procedures outlined in the                    
          regulations for furnishing respondent with additional                       
          information pertaining to a change of address of SCP, or the                
          TMP, JCB.  As a result, the address on the 1999 Form 1065, the              
          Stone Canyon address, was a proper address which to mail the                
          FPAA for 1999.  Id.                                                         
               By mailing FPAAs to multiple addressees at multiple                    
          addresses, respondent made a good faith effort to notify all                
          affected parties of the partnership adjustments, thus satisfying            
          the notice requirement of sec. 6223(a).  Crowell v.                         
          Commissioner, supra at 692-693.                                             
               B.  Beverly Glen                                                       
               On April 5, 2005, 3 days before the FPAAs were mailed,                 
          Olson telephoned Revenue Agent Smyth and informed her that the              
          Bedrosians’ address was now the Beverly Glen address.  Olson                
          stated that she informed respondent of the Beverly Glen address             
          but told respondent that the Rocco address was still the                    
          Bedrosians’ residence.  Respondent issued four FPAAs to the                 
          Beverly Glen address.                                                       
               Petitioner argues that Olson did not have power of attorney            
          for SCP or JCB, and as a result, her notification to Revenue                
          Agent Smyth was invalid.  We disagree.  Olson held power of                 
          attorney for the Bedrosians.  As a result, the Beverly Glen                 
          address was an appropriate address which to mail the FPAA in                







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