- 10 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011