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Matters Partner Wayne Caldwell, Escrow". Mr. Caldwell's
letter states as follows:
Dear Mr. Norstrud,
I am sorry that the protest letter you received from me
was inappropriate, because I was writing it on behalf of
the Partnership as the tax matters partner.
I will write another protest letter that will clearly show
and indicate that it is for the partnership "Wayne
Caldwell, Escrow." and send it to you as soon as possible.
I am enclosing a copy of your letter, so we will be sure
that we have the right entity that is to be handled.
Sincerely yours,
/s Wayne H. Caldwell
Wayne H. Caldwell,
Tax Matters Partner
Wayne Caldwell, Escrow
5952 Royal Lane, # 117
Dallas, Texas 75230
On January 7, 1987, prior to receiving a revised
protest letter from Mr. Caldwell, Mr. Norstrud received an
executed Form 872-O, Special Consent to Extend the Time to
Assess Tax Attributable to Items of a Partnership, on
behalf of the partnership. Mr. Caldwell had signed the
form in the space reserved for the tax matters partner.
Following his signature, Mr. Caldwell included the title
"Managing Partner". Mr. Norstrud signed the extension on
behalf of respondent. No other partner executed a Form
872-O extending the period of limitations for 1983. The
Form 872-O executed by Mr. Caldwell extended the period of
limitations on assessment as follows:
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