- 20 - 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 EnergyPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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