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Montgomery Street, Suite 816, San Francisco, California. On
February 3, 1998, respondent mailed the notice of deficiency to
SFWP at 555 Montgomery Street, Suite 816, San Francisco,
California.
U.S.A. Wesco Polymers, Inc. (USAWP), was incorporated under
the law of the State of California on August 20, 1993. USAWP's
EIN is 94-3187418. Chang was the president and chairman of
USAWP. USAWP filed its first Form 1120 on February 10, 1995,
covering the fiscal year beginning September 1, 1993 and ending
June 30, 1994. USAWP's address on its Form 1120 was 555
Montgomery Street, Suite 816, San Francisco, California.
On August 16, 1993, the shareholders of SFWP decided that
USAWP would take over SFWP's business operations on September 1,
1993. SFWP liquidated on December 31, 1994.
On June 20, 1996, respondent mailed a letter to Chang
attached to which were two copies of Form 872. The letter stated
that the Form 872 was provided with respect to "the examination
of your corporate tax return, Form 1120, for San Francisco Wesco
Polymers, Inc." and requested that Chang execute Form 872 because
the period of limitations "will expire in February of 1997."
The Form 872 mailed by respondent lists the name of the
taxpayer as: "USA Wesco Polymers, Inc., Successor in Interest to
San Francisco Wesco Polymers, Inc. (EIN 94-3100328)". The EIN of
the taxpayer on Form 872 listed on the upper right corner is
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