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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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