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"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's
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