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STONE CANYON PARTNERS v. COMMISSIONER

Dkt. No. 9664-07.

94 T.C.M. 618 (2007)

T.C. Memo. 2007-377

Stone Canyon Partners, JCB Stone Canyon Investments, LLC, Tax Matters Partner v. Commissioner.

United States Tax Court.

December 26, 2007.

Attorney(s) appearing for the Case

Richard E. Hodge, William E. Johnson, Steven R. Mather, and Elliott H. Kajan, for petitioner.

Michael L. Boman, for respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

This case is before us on petitioner's motion to dismiss for lack of jurisdiction pursuant to Rule 240(c) on the grounds that respondent has failed to issue a valid notice of final partnership administrative adjustment (FPAA).1 Further, respondent moved to dismiss for lack of jurisdiction on the grounds that the petition is untimely. See generally...

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