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period of limitations on the partnership's return for the 1983
tax year was April 15, 1987.
During the May 12, 1986, meeting, Mr. Farley advised Mr.
Schrmack that Mr. Jonell had resigned as general partner in 1985
and wanted no further involvement with the partnership, and that
he, Mr. Farley, was the general partner and would be the only
logical choice as TMP for the partnership because he was the only
person sufficiently knowledgeable of the partnership. Mr. Farley
and Mr. Schrmack met again on July 28, 1986. In a letter to Mr.
Schrmack mailed subsequent to this meeting, Mr. Farley
represented to Mr. Schrmack that he, Mr. Farley, was "impowered"
(sic) as the "tax matters person" for the partnership.
On October 21, 1986, Mr. Farley executed a Form 872-O,
"Special Consent to Extend the Time to Assess Tax Attributable to
Items of a Partnership" with respect to the partnership's 1983
tax year (the 1986 consent). Mr. Farley signed the form on the
line calling for the signature of the TMP. The form was executed
on behalf of respondent on November 4, 1986. Respondent did not
mail a Form 872-N (to terminate the Form 872-O special consent)
to the partnership, nor did respondent receive a Form 872-N from
the partnership.
No document was filed with respondent designating Mr. Farley
as the TMP for the partnership for 1983. The partnership did not
designate a TMP on its return for 1983. Respondent did not
designate Mr. Farley as TMP. Respondent made no determination
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