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CLOVIS I v. COMMISSIONER

Docket No. 44228-86.

88 T.C. 980 (1987)

CLOVIS I, CARL E. AND HAZEL E. LOVELL, SR., PERSONS OTHER THAN TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 21, 1987.

Attorney(s) appearing for the Case

Carl E. and Hazel E. Lovell, Sr., pro se.

Paul L. Dixon, for the respondent.

OPINION

WILLIAMS, Judge:*

This case is before us on respondent's motion to dismiss for lack of jurisdiction on the ground that respondent has not mailed a notice of final partnership administrative adjustment (FPAA) for the partnership items that are the subject of the petition. See sec. 6223(a)(2).1 The mailing of a FPAA is a prerequisite to the commencement of a partnership action. Sec. 6226...

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