- 5 - through 1989 tax years (1987-89 Cycle) commenced with an audit notification letter dated April 16, 1990. Shortly thereafter, a preaudit conference was held between petitioner and respondent's examination team, at which the parties discussed the scope and timing of the pending examination. At the preaudit conference, petitioner was informed that, because no FSC adjustments had been proposed as a result of respondent's examination of its 1984-86 Cycle, respondent would not examine FSC issues in the 1987-89 Cycle. The examination team requested, and petitioner executed, Forms 872, Consent to Extend the Time to Assess Tax, for each of the years of the 1987- 89 Cycle. During the course of the examination, respondent did not seek Forms 872 for UCFSC's corresponding tax years, nor did petitioner file any protective claims for refund or solicit any extensions of the periods of limitations for UCFSC's 1987, 1988, and 1989 tax years. During that time, petitioner did not anticipate making a redetermination of the FSC commissions paid to UCFSC during those years. The limitations periods for respondent to assess deficiencies under section 6501(a) (limitations on assessment and collection), and for UCFSC to file claims for refund under section 6511 (limitations on credit or refund), for UCFSC's 1987, 1988, and 1989 tax years expired on September 15, 1991, August 22, 1992, and September 10, 1993, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011