Denis Brody and Carol Brody - Page 15

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             intent.  According to petitioners' argument, summarized                  
             above, the person who prepared the consent on behalf of                  
             respondent thought that Mr. Brody held an interest in                    
             Thunderbird directly and did not know that Mr. Brody held                
             his interest in Thunderbird through BDB.  Petitioners                    
             contend that if respondent's agent had known, then he                    
             "would have asked all of the other partners of BDB to                    
             execute waivers".  Petitioners complain that "if this                    
             Court makes this deficiency applicable to Mr. Brody his                  
             return will then be inconsistent with the return of BDB                  
             and inconsistent with the return of all the other partners               
             of the BDB partnership."                                                 
                  Accepting petitioners' factual allegations as true for              
             purposes of this discussion, we agree that respondent's                  
             agent would have asked all partners of BDB, including                    
             petitioners, to execute waivers of the period of                         
             limitations on assessment and collection.  Prior to the                  
             enactment of the uniform audit procedures for partner-                   
             ships in sections 6221 through 6233, the Commissioner                    
             was required to obtain a consent for extension of the                    
             period of limitations from each of the partners, not                     
             the partnership.  See Staff of Joint Comm. on Taxation,                  
             General Explanation of the Revenue Provisions of the Tax                 
             Equity and Fiscal Responsibility Act of 1982, at 267 (J.                 





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