Stone Canyon Partners, JCB Stone Canyon Investments, LLC, Tax Matters Partner - Page 11




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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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