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preliminary or final notice of any partnership adjustment
concerning the 1984 return so that petitioner would have the
opportunity to stop the running of interest, ostensibly by paying
the tax. Petitioner’s letter included his name, address, Social
Security number, and respondent’s reference number but did not
disclose the amount of petitioner’s profits interest in the
Golden Gate partnership or in the two pass-through partnerships
through which he held an indirect interest in Golden Gate. In
April 1996, respondent contacted him once again, this time in
connection with the audit of Golden Gate’s 1982 return, and
requested a copy of petitioner’s Federal tax return for 1982.
Petitioner provided the return, confirmed his address and Social
Security number, and asked for documentation concerning the
expiration of the period for assessment and/or information that
would permit the opportunity to stop the accrual of interest with
respect to petitioner’s 1982 tax year.
In February 1997, respondent sent petitioner two letters.
The first informed him that he was not subject to any partnership
adjustment for either 1983 or 1984. The second letter informed
him that he was subject to a partnership adjustment concerning
Golden Gate’s 1982 returns. In April 1997, petitioner paid the
1982 deficiency in the amount of $616. In May 1997, petitioner
paid the interest due on the deficiency for tax year 1982 in the
amount of $1,798.02.
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