- 9 - information listed above and was for the purpose of authorizing the disclosure of taxpayer information concerning certain of the Hoyt Farms partnerships, not including Ranch Properties. Nowhere in the Cobb letter, the authorization, or its Exhibits 1 and 2, does a group of partners having in the aggregate a 5-percent or greater interest in Ranch Properties for tax year 1994 request recognition as a notice group or designate one of its members to receive notices on behalf of such group. See sec. 301.6223(b)- 1T, Temporary Proced. & Admin. Regs., supra. To the contrary, Exhibit 1 states that Mr. Hoyt had no “authority for authorization” as to “the two Hoyt and Sons Ranch Properties partnerships”. To apply such a broad and loose interpretation to these documents, as SGE would have the Court do, would render the specific sections of the Code and regulations useless. Accordingly, because SGE failed to meet any of the requirements to request treatment as a notice group, or as a member or designee of such a group, it is not treated under section 6223(e)(1)(B) as entitled to the notice specified in section 6223(a). According to the Schedule K-1 issued in connection with Ranch Properties’ 1994 partnership return, SGE was a 0.65-percent profit, loss, and ownership holder of Ranch Properties. SGE does not dispute that its stated interest in Ranch Properties is lessPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011