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