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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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Last modified: March 27, 2008