Union Texas International Corporation, f.k.a. Union Texas Petroleum Corporation - Page 20

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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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