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FPAA |
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If the Service does not issue a valid FPAA for a specific year, neither it nor the court can adjust partnership items for those years. This is because the IRS is permitted to send all "notice partners" copies of the FPAA notice anytime up to 60 days after the notice is sent to the tax matter partner. Consumers want tomatoes that taste garden-fresh, peaches that taste like they were just picked from the tree, and strawberries boasting flavor every bit as rich as their bright red color suggests," said Lee Frankel, FPAA President. |
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