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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.
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Last modified: May 25, 2011