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signed “Joseph O. Voyer Treasurer”. It shows the date of that
signature as February 1, 1985. It does not state the
organization, if any, of which Joseph O. Voyer was treasurer.
The partnership never had a treasurer; Mr. Voyer was never a
partner in the partnership. Mr. Voyer was an officer and
employee of AMCOR.
Neither the AVA 1984 or 1985 Forms 1065 designates any
partner as the TMP of the partnership.
5. Designation of TMP
In 1988, Deborah R. Gaither, a revenue agent employed by
respondent, was conducting an examination of various AMCOR
sponsored partnerships. In September 1988, Ms. Gaither prepared
a letter for signature by Messrs. Behrens and Schreiber, which
she carried to Messrs. Behrens and Schreiber, who signed the
letter on September 30, 1988 (the September 30 letter), and
immediately returned it to her. Pertinent portions of the
September 30 letter follow:
Sept. 30, 1988
Internal Revenue Service
24000 Avila Road
Laguna Niguel, California 92677
RE: TAX MATTERS PARTNER
Gentlemen:
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