Stone Canyon Partners, JCB Stone Canyon Investments, LLC, Tax Matters Partner - Page 12




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          for 2003 listing the Rocco address.  The 2003 Form 1040 is not              
          part of the record.  Even if the Form 1040 were part of the                 
          record, the Rocco address shown on the Form 2688 and allegedly              
          shown on the Form 1040 was not the Bedrosians’ most current                 
          address.  Olson updated respondent subsequent to the filing of              
          the Bedrosians’ Form 1040 for 2003 by notifying Revenue Agent               
          Smyth as to the North Canon and Beverly Glen addresses.                     
               Petitioner further argues that respondent sent a series of             
          correspondence to the Bedrosians at the Rocco address and                   
          therefore was aware of the Rocco address and had the Rocco                  
          address in respondent’s information base.  Additionally,                    
          petitioner notes that the Computer Generated Form 886-Z(C),                 
          Partner’s or S Corporation Shareholders’ Shares of Income, that             
          was attached to the FPAA listed the Rocco address for both                  
          Investors and JCB.  Although respondent was aware of the Rocco              
          address and in fact used the Rocco address on the Form 886-Z(C),            
          the FPAA itself was not required to be sent there.  Triangle                
          Investors Ltd. Pship. v. Commissioner, 95 T.C. at 616.  Pursuant            
          to section 301.6223(c)-1T(f), Temporary Income Tax Regs., supra,            
          respondent is not obligated to search his records for                       
          information not expressly furnished.  Petitioner did not follow             
          the procedure in the regulations, and as a result respondent was            
          not obligated to search his records for information when sending            
          the FPAA. Furthermore, the Beverly Glen address was a proper                







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