Russian Recovery Fund Ltd. v. United States

OPINION

BRUGGINK, Judge.

This Tax Equity and Fiscal Responsibility Act (“TEFRA”) action is a petition for readjustment of partnership items brought under 26 U.S.C. § 6226(a) (1986)1 by Russian Recovery Advisors, LLC. (“RRA” or “plaintiff’), as the tax matters partner for Russian Recovery Fund, LTD (“RRF”). Plaintiff alleges that the Internal Revenue Service (“IRS”) erred in its October 14, 2005 Notice of Final Partnership Administrative Adjustment for the tax year ending December 31, 2000 (“2000 FPAA”). Plaintiff contends that the 2000 FPAA was issued outside the limitations period and is…