- 3 - partners in total. Petitioners were notified by respondent on May 9, 1988, that an examination of Green Leasing was underway with respect to taxable year 1984. From August 1990 through November 1991, petitioners received several items of correspondence from CIGNA explaining the status of respondent’s ongoing examination of Green Leasing and the other partnerships. This correspondence incorporated analysis by the accounting firm Coopers & Lybrand. The first letter petitioners received, dated August 22, 1990, described a “worst case” outcome to settlement negotiations. The letter specifically stated that negotiations were ongoing and that petitioners should not expect any eventual settlement offer to contain the same terms. Petitioners filed amended Federal income tax returns for the taxable years 1983 through 1987 in December 1990 and for the taxable years 1988 and 1989 in January 1991. They paid the additional tax and interest shown thereon at the time they filed the amended returns. The IRS processed the amended returns reporting tax due (1983 through 1985) and assessed the reported tax. The IRS did not process those showing refunds (1986 through 1989) because of the unresolved issues relating to Madison Leasing. Petitioners filed the amended returns partially in response to this Court’s opinion in Thornock v. Commissioner, 94 T.C. 439 (1990).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011