Laurence L. and Patricia Jacobs - Page 7




                                        - 7 -                                         
          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           






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