- 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