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penalties. Agent McBrien testified that the examination group
forwarded the Schedules K-1 to Quality Review, and that his group
no longer had possession of the forms after the case was sent to
Quality Review. During September 1989, the examination group
finished its work and returned the file to Quality Review. The
record is silent as to what happened with the TLP case from
September 1989, through November 17, 1991.
November 18, 1991, Through July 8, 1996
On November 18, 1991, the FSC issued the limited partners a
60-day letter for the 1983 tax year proposing to disallow the R&D
losses based upon Agent McBrien's findings. By letter dated
January 15, 1992, TLP's tax matters partner requested an appeal
of the 60-day letter.
On March 19, 1992, the case was assigned to Appeals Officer
Beth Thurston to resolve the disputed issues. She checked the
case into her inventory, verified that the period of limitations
had not expired and that there were sufficient documents in the
file, and reviewed the issues to see if they were sufficiently
developed to be considered by Appeals.
TLP's first representative during the Appeals process was
Mr. Reising. Appeals Officer Thurston and Mr. Reising discussed
the issues of the case during a telephone conference on June 9,
1992. During December 1992, Appeals Officer Thurston mailed an
appointment letter to Mr. Reising. Mr. Reising was involved with
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