Caltex Oil Venture, Caltex Management Corporation, Tax Matters Partner v. Commissioner

OPINION

Gustafson, Judge:

On November 13, 2007, the Internal Revenue Service (irs) issued a notice of final partnership administrative adjustment (FPAA) for taxable year ending December 31, 1999, to Caltex Management Corp., the tax matters partner (tmp) of Caltex Oil Venture. (It is the latter entity — Caltex Oil Venture — to which we refer herein as “Caltex”.) This case is a partnership-level action based on a petition filed by the TMP pursuant to section 6226. The matter is currently before the Court on the IRS’s motion for partial summary judgment filed pursuant to Rule 121, which asks us to…