The district court did not err in denying appellant Metro’s claim under 26 U.S.C. 6226 because no final partnership administrative adjustment was issued. The Internal Revenue Service made no adjustment to the partnership return. See Atlantic Richfield Co. v. Department of Treasury, 1996 WL 788366 (D.D.C. 1996).

The district court properly dismissed appellant Metro’s § 6228 claim because no valid administrative-adjustment request (IRS Form 8082) was filed. The Form 8082 filed was not completed in such a way as to constitute a valid Administrative Adjustment Request. No contrary argument is presented in appellants’ brief.

AFFIRMED.