Bedrosian

Petitioners-Appellants John and Judith Bedrosian appeal three orders of the Tax Court dismissing in whole or in part their challenges to three different notices relating to the same underlying adjustments for the tax years 1999 and 2000. We have jurisdiction over two of these appeals under 26 U.S.C. § 7482 (a)(1). We affirm in part and dismiss in part.

In the first appeal, the Bedrosians challenge a notice of final partnership administrative adjustment (FPAA) that the IRS mailed on April 8, 2005, pursuant to 26 U.S.C. § 6223 (a)(2). The FPAA asserted adjustments to the 1999 tax return of Stone Canyon Partners, a short-lived partnership formed by two companies of which the Bedrosians are the sole owners. The FPAA invalidated transactions between the closely held companies and the partnership, disallowed a loss claimed by the partnership, and imposed an accuracy-related penalty. The Bedrosians filed a petition for readjustment of the FPAA in the Tax Court on May 1, 2007, more than 90 days after the FPAA was mailed. See 26 U.S.C. § 6226 (a). Because we determine that the IRS validly mailed the FPAA to the Bedrosians, we affirm the Tax Court’s dismissal for lack of jurisdiction of…