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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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