- 13 - "Tax Matters Partner". Agent Schieck never received a response to the letters he sent in July 1989. Sometime in 1989, Mr. Denny received a telephone call from one of respondent's agents. The agent said that Mr. Denny was the tax matters partner because he held the largest profits interest in the partnership. However, no action was taken by respondent, Mr. Denny, or any other member of the partnership to formally designate Mr. Denny as tax matters partner. In August 1989, Agent Schieck scheduled a conference to administratively close the partnership's case. Mr. Caldwell appeared at the conference and was accompanied by Mr. Raymond Woody, another partner. During the conference, Mr. Caldwell asked to see the credentials and delegation orders of respondent's representatives and was otherwise uncooperative. Because Mr. Caldwell had not brought the documentation that Agent Schieck had requested, the meeting was quickly concluded. Sometime thereafter, the case was returned to respondent's Appeals Office in Dallas, Texas, and Mr. Norstrud prepared a so-called FPAA package, a group of documents, including a notice of FPAA and an explanation of adjustments, that are required under respondent'sPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011