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PETALUMA FX PARTNERS, LLC v. COMMISSIONER

Dkt. No. 24717-05.

94 T.C.M. 237 (2007)

T.C. Memo. 2007-254

Petaluma FX Partners, LLC, Ronald Scott Vanderbeek, a Partner Other than the Tax Matters Partner v. Commissioner.

United States Tax Court.

August 28, 2007.

Attorney(s) appearing for the Case

Edward M. Robbins, Jr., for petitioner.

Jason M. Kuratnick and Gerald A. Thorpe, for respondent.

MEMORANDUM OPINION

GOEKE, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction.1 Respondent argues that the Court lacks jurisdiction because the notice of final partnership administrative adjustment (FPAA) dated July 28, 2005, upon which the petition is based, was issued for the taxable year of Petaluma FX Partners, LLC (Petaluma), ending August 31, 2000, and thus does not confer jurisdiction...

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