Wise Guys Holdings, LLC, Peter J. Forster, Tax Matters Partner v. Commissioner

140 T.C. No. 8

UNITED STATES TAX COURT WISE GUYS HOLDINGS, LLC, PETER J. FORSTER, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6643-12. Filed April 22, 2013. R mailed to P, as W’s tax matters partner (TMP), a notice of final partnership administrative adjustment (FPAA) for W’s 2007 taxable year. Approximately nine months later, R (through an office different from the office that mailed the FPAA) mailed to P, as W’s TMP, a second FPAA for W’s 2007 taxable year. The first FPAA and the second FPAA are similar in content but are different in the…