S. Byrne Doyle and Barbara S. Doyle - Page 5

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          of Shane was transferred to the Danish Breeder's Group of                   
          Copenhagen, Denmark (Danish Breeder's), in the records of the               
          USTA.  An unsigned copy of the partnership agreement attached to            
          the private placement memorandum was submitted in March 1987 to             
          the USTA in order to show the source of authority to sell Shane             
          to Danish Breeder's.                                                        
               Procedural Background                                                  
               The partnership filed returns on a calendar year basis and             
          filed its 1983 return timely on April 15, 1984.  In 1986,                   
          respondent was conducting an audit of the partnership's 1983 tax            
          year.                                                                       
              At all times, Mr. Farley handled the audit with Revenue                
          Agent James Schrmack.  On or about May 12, 1986, Mr. Schrmack and           
          Mr. Farley met to go over the audit.  During this meeting, Mr.              
          Schrmack advised Mr. Farley that a notice of the beginning of               
          examination for 1983 had to be sent out to the partnership and              
          that a tax matters partner (TMP) had to be named for the                    
          partnership.  Because it was probable that the period of                    
          limitations would have to be extended, Mr. Schrmack needed                  
          someone with whom he could conduct the examination, and someone             
          who could sign a consent to extend the period of limitations.               
          Mr. Schrmack advised Mr. Farley that, in the event a TMP was not            
          named, Mr. Schrmack would have to get Mr. Jonell to sign such a             
          consent.  Absent a valid extension, the expiration date for the             






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