OPINION
JACOBS, Judge:
This matter is before the Court on petitioner's motion to dismiss for lack of jurisdiction (petitioner's motion), the resolution of which turns on whether respondent should have issued a notice of final partnership administrative adjustment (FPAA) to the tax matters partner (TMP) of NASCO Corporate Finance Consultants, LLC (NASCO), pursuant to the procedural rules of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA...
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