Helen M. Korchak - Page 20

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          1982 joint tax return about the claimed $58,089 Madison Recycling           
          loss and the claimed Madison Recycling tax credits of $114,407,             
          which she did not, Mr. Korchak would have assured her that that             
          claimed loss and those claimed credits were proper.                         
               On May 1, 1983, petitioner and Mr. Korchak signed the 1982             
          joint tax return, and on May 6, 1983, they filed it with the IRS.           
               On or about December 24, 1987, respondent issued a Notice of           
          Final Partnership Administrative Adjustment to Madison Recy-                
          cling’s tax matters partner for, inter alia, Madison Recycling’s            
          taxable year ended December 31, 1982 (FPAA).  In the FPAA,                  
          respondent, inter alia, disallowed Madison Recycling’s claimed              
          $704,111 loss and reduced to $0 Madison Recycling’s claimed                 
          $7,000,000 basis for investment tax credit purposes and business            
          energy investment tax credit purposes (respondent’s reduction to            
          $0 of Madison Recycling’s claimed basis).                                   
               On February 16, 1988, respondent sent a copy of the FPAA to            
          Mr. Korchak and petitioner in an envelope addressed to both of              
          them.  Consistent with his practice of opening the family’s mail,           
          Mr. Korchak opened that envelope and reviewed the FPAA.  He                 
          showed the FPAA to petitioner because he believed that she should           
          be aware that the IRS had raised questions about Madison Recy-              
          cling’s 1982 return, which, in turn, raised questions about the             
          claimed $58,089 Madison Recycling loss and claimed Madison                  
          Recycling tax credits of $114,407 in their 1982 joint tax return.           






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