Seymour and Beatrice Leffert - Page 18
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March 14, 1990, Through October 22, 1995
The record discloses only sporadic and inattentive IRS
activity in the Blue Gem case with respect to the period from
March 14, 1990, through October 22, 1995. During this 5-year
period, Appeals Officer Koniarski appears to have worked on the
Blue Gem case only intermittently for brief amounts of time.
Indeed, in his testimony at trial, Mr. Koniarski acknowledged
that no further factual development of the case was needed during
this period because all necessary factual development had been
completed during the revenue agent’s earlier examination.
The record further reveals that neither the Blue Gem TMP nor
any of the notice partners except 7201 Associates chose to
participate in the administrative appeal of the Blue Gem case.
As Appeals Officer Koniarski stated in his supporting statement
recommending issuance of FPAA’s with respect to Blue Gem’s 1982
and 1983 taxable years, the Blue Gem TMP never filed any protest;
the only protest filed was Mr. Leffert’s protest letter on behalf
of 7201 Associates.
In his testimony, Appeals Officer Koniarski claimed the Blue
Gem TMP had been uncooperative, and Mr. Koniarski attributed his
inability to close out and conclude the Blue Gem case sooner, in
part, to this lack of cooperation by the Blue Gem TMP. The Blue
Gem TMP had postponed the Appeals conference originally scheduled
by Mr. Koniarski. According to Mr. Koniarski, his subsequent
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