Laurence L. and Patricia Jacobs - Page 3




                                        - 3 -                                         
          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.              





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011