- 7 -
with each partner's percentage interest in the partnership,
and is treated as "Property Eligible for Investment
Credit."
The Form 1065, U.S. Partnership Return of Income, that
was promulgated by the Commissioner for 1983 did not
contain a space for the designation of the tax matters
partner, and nothing on, or attached to, either of the
returns filed on behalf of the partnership for 1983
expressly identifies Mr. Caldwell or anyone else as the
tax matters partner. The document attached to both returns
as "Schedule B", entitled "Election to Pass Investment Tax
Credit from Lessor to Lessee", was executed on the
partnership's behalf by Mr. Caldwell as "Managing Partner".
On or about March 28, 1985, respondent initiated an
examination of the partnership's 1983 return. A represen-
tative of respondent sent a letter to Mr. Caldwell dated
March 28, 1985, which states: "This is your notice of the
beginning of an administrative proceeding at the partner-
ship level with respect to partnership items." The letter
further states: "An appointment has been scheduled for
9:00 a.m., May 2, 1985, at 5952 Royal Lane, #177." The
letter concludes with the following:
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