Laurence L. and Patricia Jacobs - Page 4




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          for TLP's 1983 year indefinitely.  The extension of the period of           
          limitations could have been terminated if either TLP's tax                  
          matters partner or its attorney had submitted a Form 872-N, but             
          none was ever submitted.5  The Form 872-O was not terminated                
          until notices of final partnership administrative adjustment                
          (FPAA) were issued to the tax matters partner and to the limited            
          partners.                                                                   
               During the examination, Agent McBrien experienced                      
          difficulties obtaining from the tax matters partner various legal           
          and business documents relating to the R&D expenses.  Agent                 
          McBrien also had to make a number of efforts to locate and                  
          compile the limited partners' Schedules K-1, Partner's Share of             
          Income, Credits, Deductions, Etc.  The Schedules K-1 were needed            
          to determine the percentage of each limited partner's allocable             
          loss.  Agent McBrien made at least two trips to the tax matters             
          partner's house in San Clemente, California, to secure the forms.           
          It was important to obtain the Schedules K-1 from the tax matters           
          partner instead of the Fresno Service Center (FSC) in order to              
          expedite the examination.  Obtaining the forms from Fresno could            
          take up to three times longer than obtaining copies from the tax            
          matters partner.  By the close of the examination, Agent McBrien            



          5    Had a Form 872-N been submitted, respondent would have been            
          required to issue a notice of final partnership administrative              
          adjustment within 90 days of receiving the Form 872-N.                      





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