Seymour and Beatrice Leffert - Page 5




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          final partnership administrative adjustment (FPAA) to the Blue              
          Gem TMP and notice partners for the partnership’s 1982 and 1983             
          years.                                                                      
               From November 5, 1986, when the special consents were                  
          signed, to January 1988, the record is silent regarding what, if            
          anything, was done by Revenue Agent Vassalo or by any other IRS             
          representative in connection with the Blue Gem examination.  On             
          January 25, 1988, the Blue Gem Associates case was transferred              
          from Revenue Agent Vassalo to Revenue Agent Melquiades Bravo for            
          purposes of closing the case.  On February 10, 1988, Revenue                
          Agent Bravo forwarded the 60-day package, consisting of Letter              
          1827, 60-day letter, Form 870-L, Agreement to Assessment and                
          Collection of Deficiencies in Tax for Partnership Adjustments,              
          Additions to Tax, and Affected Items, and Form 4605-A, Revenue              
          Agent Report (collectively, the 60-day letter), to the Brookhaven           
          Service Center for mailing to the Blue Gem TMP and all notice               
          partners.                                                                   
               On August 22, 1988, the IRS mailed a 60-day letter to the              
          Blue Gem TMP and notice partners of Blue Gem, proposing to adjust           
          the partnership’s 1982 and 1983 returns.                                    
               On September 20, 1988, the Brookhaven Service Center                   
          received a protest from 7201 Associates contesting the proposed             
          adjustments in the 60-day letter and requesting an Appeals                  
          conference.  Mr. Leffert filed the protest on behalf of 7201                






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