- 16 - 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:Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011