Triangle Investors P'ship v. Comm'r
United States Tax Court
R issued an FPAA to a partnership that had not formally designated a tax matters partner. The FPAA was mailed to the address appearing on the partnership's return for the year in issue, although a revenue agent who performed an examination of the partnership's affairs had actual notice of the partnership's current address, which was not the address on the return. Later, R issued the FPAA to notice partners.
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R issued an FPAA to a partnership that had not formally designated a tax matters partner. The FPAA was mailed to the address appearing on the partnership's return for the year in issue, although a revenue agent who performed an examination of the partnership's affairs had actual notice of the partnership's current address, which was not the address on the return. Later, R issued the FPAA to notice partners. P received the FPAA in sufficient time to file a timely petition as a notice partner. P filed an untimely petition for readjustment. Held, the FPAA was validly issued to the "Tax Matters…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This matter is before the Court on respondent’s motion to dismiss for lack of jurisdiction. (Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the year in issue and all Rule references are to the Tax Court Rules of Practice and Procedure.) The issue for decision is whether the notice of final partnership administrative adjustment issued in this case was valid.
Background
Respondent determined adjustments to the partnership return of Triangle Investors Limited Partnership (Triangle Investors) for its 1984 taxable year as…
2Cases cited6 opinions
- Houghton v. CommissionerUnited States Tax Court · 1967
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- Clovis I v. CommissionerUnited States Tax Court · 1987
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- Seneca, Ltd. v. CommissionerUnited States Tax Court · 1989
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