§4227 — Cross reference
2 cases·1 distinguished·1 cited
Statute Text — 26 U.S.C. §4227
For exception for a sale to an Indian tribal government (or its subdivision) for the exclusive use of an Indian tribal government (or its subdivision), see section 7871.
2 Citing Cases
authorized to mail such notices by registered or certified mail, section 6223(a) is silent with respect to the type of mail to be used for an FPAA.2 2 Respondent’s practice is to send FPAA’s by certified mail. 1 Audit, Internal Revenue Manual (CCH), sec. 4227.47(9), at 7233-21. This practice is similar to respondent’s practice for mailing notices of deficiency in the United States. Id. (continued...) - 8 - To comply with section 6223(a), the Commissioner is required to use the names, addresses,
ncluding a notice of FPAA and an explanation of adjustments, that are required under respondent's - 14 - procedures to issue a notice of FPAA to the tax matters partner and the notice partners. See generally 1 Audit, Internal Revenue Manual (CCH), sec. 4227.47, at 7233-20. In the notice of FPAA prepared by Mr. Norstrud, respondent determined that in computing the amount of property eligible for investment credit for 1983, the partnership is not entitled to take into account, as qualifying sectio