- 31 - L. Schreiber, a general partner in the partnership, as the TMP of the partnership for 1985 and shows his address as “5000 Birch Street, Suite 610, Newport Beach, California 92660". The 1985 AVA Form 1065 shows the partnership’s address as care of AMCOR, “5000 BIRCH ST., STE 610, EAST TOWER, NEWPORT BEACH CA 92660". AVA has failed to show that the partnership’s address was any different on September 30, 1988, or that correspondence addressed to it care of George L. Schreiber, who also signed the September 30 letter as vice president of AMCOR, would not have reached the partnership. We find that the partnership was identified by address in the September 30 letter. Moreover, the September 30 letter was prepared by Deborah Gaither, a revenue agent employed by respondent who was examining various AMCOR- sponsored partnerships. The circumstances surrounding her preparation of that letter and its signature by Messrs. Behrens and Schreiber convince us that there could have been no confusion as to what partnerships were the subject of that letter and that any technical inadequacy in that regard is immaterial. The first sentence of section 301.6231(a)(7)-1T(e), Temporary Proced. & Admin. Regs., supra, specifies that the statement designating a TMP be filed with the service center with which the partnership return was filed. AVA argues that its failure to file the September 30 letter with the service center is fatal to its validity. Respondent argues that, since thePage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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