- 9 - agreement, that there was "no overriding partnership agreement for Oceanic Leasing," and that Oceanic Leasing was a collection of separate partnerships. The revenue agent determined that the Schedules K-l attached to the Form 1065 did not reconcile with the losses reported on the return or equal 100-percent interests in the partnership. The agent began identifying various individuals who had claimed Oceanic Leasing partnership losses in order to arrive at interests totaling 100 percent. The revenue agent solicited Hardin's appointment as tax matters partner and secured from him an agreement to extend the period of limitations on adjustments arising out of the 1986 Form 1065. She believed that she was operating under the partnership provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648, codified at sections 6221-6232. The Notice of Final Partnership Administrative Adjustment (FPAA) that is the subject of this proceeding was mailed December 31, 1992, to Douglas F. Spaulding, as tax matters partner. The partnership was identified as Oceanic Leasing at the Sausalito address with EIN 94-2870681. All of the losses and credits claimed on the 1986 Form 1065 were disallowed. At the time of the notice, the revenue agent had identified at least 29 persons who had claimed losses from Oceanic Leasing with the same identification number as the partnership Form 1065 that she wasPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011