- 11 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008