- 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 12/31/89Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
Last modified: May 25, 2011