Stone Canyon Partners, JCB Stone Canyon Investments, LLC, Tax Matters Partner - Page 13




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          address to which respondent could mail the FPAAs to the                     
          Bedrosians as individuals and as the indirect partners of JCB               
          and Investors.                                                              
          II.  Respondent’s Motion To Dismiss                                         
               Respondent moves to dismiss the case for lack of                       
          jurisdiction on the grounds that the petition was untimely                  
          pursuant to section 6226(a) and (b).  The petition was filed on             
          May 1, 2007, more than 2 years after the FPAA was sent.                     
          Petitioner concedes that if the FPAA is determined to be valid,             
          then the petition is untimely.  Because we hold that the FPAA               
          met the notice requirement of section 6223 and thus was valid,              
          the petition is therefore untimely.  Consequently, we shall                 
          grant respondent’s motion to dismiss for lack of jurisdiction               
          and deny petitioner’s motion to dismiss.                                    
               In reaching all of our holdings herein, we have considered             
          all arguments made by the parties, and, to the extent not                   
          mentioned above, we find them to be irrelevant or without merit.            
               To reflect the foregoing,                                              

                                        An appropriate order and order                
                                   of dismissal will be entered.                      












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