Wayne Caldwell Escrow Partnership, Roy Dimon, John and Mary Schuenemann, Joseph and Louise O'Neal, Charles and Lovetta Niven, Chalton and Cynthia Thomas, Partners Other Than the Tax Matters Partner - Page 11

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                       (1) The amount of any Federal income tax                       
                  with respect to any person on any partnership                       
                  items(s) for the above named partnership for                        
                  the period(s) ended  December 31, 1983  may be                      
                  assessed on or before the 90th (ninetieth) day                      
                  after: (a) the Internal Revenue Service office                      
                  considering the case receives Form 872-N, Notice                    
                  of Termination of Special Consent to Extend the                     
                  Time to Assess Tax Attributable to Items of a                       
                  Partnership, from the partnership; or (b) the                       
                  Internal Revenue Service mails Form 872-N to the                    
                  partnership.  If a notice of Final Partnership                      
                  Administrative Adjustment is sent to the part-                      
                  nership, the time for assessing the tax for                         
                  the period(s) stated in the notice of Final                         
                  Partnership Adjustment will not end until 1 year                    
                  after the date on which the determination of the                    
                  partnership items becomes final.                                    

                  Mr. Caldwell sent a revised protest letter that was                 
             dated January 21, 1987, and signed on January 31, 1987.                  
             In the letter, Mr. Caldwell identifies himself as "Tax                   
             Matters Partner".                                                        
                  Mr. Caldwell did not provide the documents that had                 
             been requested by Mr. Norstrud, including a copy of the                  
             video.  As a result, respondent's Appeals Office returned                
             the case to the District Office for further development                  
             and summons enforcement.                                                 
                  At a summons enforcement hearing before a United                    
             States District Court, Mr. Caldwell was present as                       
             a party, but he did not provide the records summoned.                    








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