- 4 -
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.
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