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three Forms 872 from the Internal Revenue Service (IRS) which
extended the assessment date to June 30, 1993, Cliett presented
it for signature to Lobliner, his supervisor during 1992. Upon
receiving the last two Forms 872 which extended the assessment
date to December 31, 1993, and June 30, 1994, respectively,
Cliett presented them for signature to Markowitz, who became his
supervisor sometime in 1993. Cliett alleges, however, that when
he presented the last three Forms 872 for signature to Lobliner
and Markowitz he did not know that New Petroleum had dissolved.
Cliett claims that he was not aware of the merger, because his
payroll checks failed to identify the specific entity for which
he worked, and he did not pay "much attention" to the Forms W-2
that he received.
We find Cliett's testimony to be implausible given his
extensive tax and accounting background, coupled with his vast
knowledge of petitioners' business organization and operations.
Cliett testified that he has worked nearly 30 years for
petitioners or one of their affiliated corporations, that he is
the supervisor for tax audits, and he is familiar with the
business organization and operations of the Union Texas
companies. At trial, Cliett was easily able to identify each
Union Texas company, to delineate the various departments within
each corporation, and to describe the primary functions of each
division within the various corporate departments. Thus, it is
most difficult to believe that at the time the last three Forms
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