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referral that resulted in a criminal investigation of AMCOR-
related individuals did not occur until October 25, 1988, almost
1 month after he signed the AVA Form 872-P for 1985. See Crop
Associates-1986 v. Commissioner, T.C. Memo. 2000-216. Also, in
Crops Associates-1986, we did not find, as the petitioner therein
requested, that the IRS misled the partners about the existence
of a criminal investigation. Nor did we find that the IRS
instructed the general partner to say nothing about such an
investigation.
f. Conclusion
We find that George L. Schreiber was the TMP of the
partnership on September 30, 1988, the day he executed the AVA
Form 872-P for 1985. The AVA Form 872-P was, thus, effective to
extend the 3-year period for all of the partners of the
partnership for 1985. The AVA FPAA was timely issued before
expiration of the section 6229(a) assessment period with respect
to the partnership’s 1985 taxable year.
IV. AVF
A. FINDINGS OF FACT
AVF, a calendar-year taxpayer, is a California limited
partnership formed in 1985 pursuant to the CRLPA.
For 1985, AVF timely made a return of income (the AVF 1985
Form 1065) to respondent’s Fresno, California, service center.
The AVF 1985 Form 1065 shows AVF’s address as: C/O AMCOR, “5000
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