- 33 -
During the partnership audit proceedings, Winer signed Forms
872-P, Consent to Extend the Time to Assess Tax Attributable to
Items of a Partnership (hereinafter the consents), to extend the
period of limitations as TMP of Davenport under section
6229(b)(1)(B).6 According to Winer, he signed the consents in
order to avoid immediate assessments' being made against the
investors. Every time Winer received a request to sign a consent
to extend the statutory period of limitations he would call his
attorney or Gordon for advice. Winer stopped signing the
consents in late 1988, after one of his attorneys told him to
stop signing the consents in order to "wait and see what happens
in Tax Court."
6 The dates of the extension forms signed by Winer were as
follows:
Taxable Year 1982
Signed by Winer Signed by IRS Extension Date
10/08/85 10/30/85 12/31/87
04/29/87 05/03/87 12/31/88
11/19/87 12/10/87 12/31/89
Taxable Year 1983
08/26/86 09/22/86 12/31/87
04/29/87 05/03/87 12/31/88
11/19/87 12/10/87 12/31/89
Taxable Year 1984
09/29/87 10/06/87 12/31/88
11/19/87 12/10/87 12/31/89
Taxable Year 1985
11/01/88 11/03/88 12/31/89
Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 NextLast modified: May 25, 2011