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not know was that there had been another reorganization in which
New Petroleum merged with Energy, and as of December 31, 1991,
ceased to exist. As a result of the merger, New Petroleum no
longer had authority to extend the period of limitations after
December 31, 1991. Yet, New Petroleum, through its former
officers, Sanford M. Lobliner (Lobliner), and M.N. Markowitz
(Markowitz),6 executed the following three Forms 872 after it had
merged out of existence:
Extended Date Date New Petroleum Signed Date Respondent Signed
6/30/93 7/22/92 8/24/92
12/31/93 1/14/93 2/11/93
6/30/94 7/27/93 7/30/93
Each of these three consents was prepared by respondent's
Appeals Office in Houston, Texas. Each consent identified the
taxpayer as "Union Texas Petroleum Corporation (formerly Union
Texas Properties Corporation) (Successor to Union Texas Petroleum
Corporation 74-6044301)" and listed the EIN as 76-0125286. The
consents should have identified the taxpayer for 1983 and 1984 as
Union Texas International Corporation, F.K.A. Union Texas
Petroleum Corporation, and for 1985 as Union Texas Petroleum
Energy Corporation, successor by merger to Union Texas Petroleum
Corporation, F.K.A. Union Texas Properties Corporation. When New
Petroleum returned the consents to respondent, the Form 872
extending the assessment date to June 30, 1993, bore Lobliner's
signature, and the two Forms 872 extending the assessment dates
6 In 1992 and 1993, respectively, Lobliner and Markowitz were
the vice presidents of Energy and would have had authority to
have properly prepared a Form 872 on petitioners' behalf.
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