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or deceit on the part of the IRS." (Emphasis added.) Petitioner
has failed to make the requisite showings.
It is true that, by the FPAA, respondent made adjustments to
the 1986 partnership return. Undoubtedly, some examination of
the 1986 partnership return preceded the FPAA. Nevertheless,
petitioner has failed to prove that, in connection with that
examination, respondent misrepresented anything to him or to
anyone else. Revenue Agent Tadlock commenced an examination of
certain AMCOR-sponsored partnerships in 1987 (the AMCOR
partnerships examination). He continued that examination through
July 1988, when his participation ended, and the examination was
continued by Revenue Agent Gaither, sporadically, until January
1990. Petitioner has failed to prove that the 1986 partnership
return was the subject of either agent’s examination. He has
failed to prove that Ms. Gaither obtained any documents relating
to the 1986 partnership return on her visit to AMCOR commencing
on October 17, 1988. He has failed to prove that the 1986
partnership return was the subject of the AMCOR corporate
examination carried on by Revenue Agent Capobianco. Indeed,
petitioner has failed to prove even the date on which the
examination of the 1986 partnership return commenced or who
conducted that examination.
Even assuming some misrepresentation, petitioner has failed
to show any prejudice to the partnership or that any evidence
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