Seymour and Beatrice Leffert - Page 4




                                        - 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.                                                                 





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