- 11 - (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.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