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of sections 6221-6234. In May 1984, respondent selected TLP's
1983 partnership return for examination. The principal issue
during the examination was the deductibility of research and
development (R&D) costs of $1,885,500 for 1983.
April 1, 1985, Through August 1987
On April 1, 1985, respondent mailed notices of beginning
administrative proceedings to the individual limited partners of
TLP. This was the first time that respondent notified the
limited partners in writing that the partnership return for 1983
was under examination. The first revenue agent to work on the
examination of TLP's 1983 return was Jean Dosil. Agent Dosil
began gathering research materials and analyzing the R&D issue.
Later, Agent Dosil was reassigned to respondent's Appeals Office,
and by January 1986, the partnership examination was reassigned
to Revenue Agent Fred McBrien.
Throughout his examination, Agent McBrien dealt with two
representatives of TLP, its tax matters partner, John Knoke,4 and
its attorney, William Reising. By September 24, 1986, TLP and
respondent executed a Form 872-O, signed by the tax matters
partner and Mr. Reising, which extended the period of limitations
3(...continued)
cartoon programs and sold as a three-dimensional toy and game
with a record that could feed off the popularity and recognition
of the cartoon program.
4 John Knoke is the general partner of TLP and has chief
decision-making responsibility and control over its operation.
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