- 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 withPage: 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