- 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