Oceanic Leasing, Douglas F. Spaulding, Tax Matters Partner - Page 9

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          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 was             





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