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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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Last modified: May 25, 2011