- 4 - On August 9, 1985, Revenue Agent Vassalo requested approval to begin a TEFRA flowthrough examination with respect to Blue Gem. His request was approved by the IRS District Director on August 23, 1985. On September 4, 1985, the IRS sent a notice of the beginning of an administrative proceeding (NBAP) to the Blue Gem TMP. On November 20, 1985, NBAP’s were sent to all notice partners of Blue Gem, including 7201 Associates. Revenue Agent Vassalo held meetings, conducted interviews, arranged for the preparation of an IRS engineering report, and otherwise continued his examination of Blue Gem through November 1986. On November 5, 1986, representatives of the IRS and the Blue Gem TMP executed Forms 872-O, Special Consent to Extend the Time to Assess Tax Attributable to Items of a Partnership (special consents), which extended the period of limitations on assessment for Blue Gem’s 1982 and 1983 years indefinitely. Although the special consents could have been terminated if Blue Gem had submitted to the IRS a Form 872-N, Notice of Termination of Special Consent to Extend the Time to Assess Tax Attributable to Items of a Partnership, none was ever submitted.4 The special consents were still in effect when respondent issued notices of 4If a Form 872-N, Notice of Termination of Special Consent to Extend the Time to Assess Tax Attributable to Items of a Partnership, had been submitted, respondent would have had 90 days to issue a notice of final partnership administrative adjustment.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