Union Texas International Corporation, f.k.a. Union Texas Petroleum Corporation - Page 7

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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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