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tax audit of petitioners for the taxable years in issue, nearly
18 months after the last consent was signed, to the agents or
Appeals officers conducting the WPT examination. Cf. King v.
Commissioner, 857 F.2d 676, 680 (9th Cir. 1988) (adopting general
theory that knowledge acquired by the IRS in unrelated
investigations is not necessarily imputed from one division to
another and citing United States v. Zolla, 724 F.2d 808, 810-811
(9th Cir. 1984)), affg. 88 T.C. 1042 (1987). Furthermore, we
find that New Petroleum did not provide respondent with notice of
the merger by filing Forms 940 and 941 in 1991 (employment tax
filings), because, as in the income tax situation, those filings
address a different tax, a different form, and are subject to
review by a different IRS division. Id.
With respect to the information available to the WPT agents
in the IRS' computer system, the record establishes that although
a computer updating procedure existed for income tax return
audits which would have reflected a change in New Petroleum's
corporate status, there was no such system in place for audits of
WPT or employment tax returns. At trial, Revenue
Agent Bruce Rhames (Agent Rhames), the group manager assigned to
conduct the WPT examination for 1985, credibly testified that
where, as in the instant cases, the income tax returns were not
under his control and something changed which did not pertain
exactly to his taxpayer, such as a change in the taxpayer's name,
its EIN, or the amount of tax paid, he was not notified of the
change. Rhames explained that New Petroleum's merger into Energy
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