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order to notify the Bedrosians. Respondent was permitted to
provide notice to an indirect partner pursuant to section
6223(c)(3). See also Murphy v. Commissioner, 129 T.C. __
(2007). The Bedrosians wholly owned JCB and Investors, pass-
through entities. Sending notice to Mr. or Mrs. Bedrosian, as
an indirect partner, at the address Olson provided to respondent
3 days before the FPAA was mailed was proper. Olson did have
power of attorney for the Bedrosians as individuals, and thus
the FPAAs mailed in care of or in the name of Mr. or Mrs.
Bedrosian at the Beverly Glen address satisfy section 6223.
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, 102 T.C. 683, 692-693 (1994).
C. Rocco
Petitioner argues that the Rocco address was the required
address to give the partners notice of the FPAA. On August 13,
2004, the Bedrosians filed a Form 2688 listing the Rocco
address. Petitioner argues that this put respondent on notice
that the Rocco address was the valid address for the Bedrosians
as individuals.
Petitioner further claims that on October 15, 2004, the
Bedrosians filed a Form 1040, U.S. Individual Income Tax Return,
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