- 17 -
Dept. of the Treasury
Internal Revenue Service
1100 Commerce Street
Dallas, Texas 75242
Att: Mr. D. Norstrud
Reference (a) Form (Letter 1827(DO))dtd. Jun 02,1986
Exhibit 1 (attached thereto) dated Nov.
14,1985 by Mike Bedford
(b) Form Letter 1807(DO) dated July 26,1989
(certified mail # P 470 982 148) enclosed
summary report
(c) Letter to District Counsel from James M.
Schieck dated Sept. 1, 1989
Enclosure (1) Form Letter 1830(AO) dtd Jan.28,1991, to
Wayne H. Caldwell from Jacob C. Meyer,
Associate Chief, Appeals.
(2) Letter to H. Elliot from Caldwell dtd.
Aug.1,1986)[sic]
Dear Mr. Norstrud,
I am in receipt of enclosure (1) document naming you as
the person to contact for the issuing Appeals section, regarding
the disposition of matters relating to Wayne H. Caldwell, Escrow
a partnership.
At the time of the appeal in question, I was the Tax
Matters Partner for the above partnership and the protest and
appeal (see enclosure (2)) I sent to your section was in regard
to a proposed adjustment to the Partnership tax return (Form
1065) for the year 1983. Exhibit (1) to reference (a) set forth
certain statements and issues as the bases for the proposed
adjustments. These allegation [sic] were in error and I was
given 60 days to protest and appeal them.
The Statements and Issues that were protested were later
amended and changed and new ones resubmitted as a summary report
attached to reference (b). A closing conference was scheduled
for August 28,1989, and the case was closed August 29,1989 (see
reference (c)).
Based on the above ,it [sic] appears the enclosure (1)
letter is untimely from the appeal filed by enclosure (2) or is
an attempt to reopen the case. The latter places this action
outside the statute of limitation [sic], and I therefore
consider this letter my Notice to you that this activity is
outside the statute of limitation [sic] and Demand that you
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: May 25, 2011