- 5 - final partnership administrative adjustment (FPAA) to the Blue Gem TMP and notice partners for the partnership’s 1982 and 1983 years. From November 5, 1986, when the special consents were signed, to January 1988, the record is silent regarding what, if anything, was done by Revenue Agent Vassalo or by any other IRS representative in connection with the Blue Gem examination. On January 25, 1988, the Blue Gem Associates case was transferred from Revenue Agent Vassalo to Revenue Agent Melquiades Bravo for purposes of closing the case. On February 10, 1988, Revenue Agent Bravo forwarded the 60-day package, consisting of Letter 1827, 60-day letter, Form 870-L, Agreement to Assessment and Collection of Deficiencies in Tax for Partnership Adjustments, Additions to Tax, and Affected Items, and Form 4605-A, Revenue Agent Report (collectively, the 60-day letter), to the Brookhaven Service Center for mailing to the Blue Gem TMP and all notice partners. On August 22, 1988, the IRS mailed a 60-day letter to the Blue Gem TMP and notice partners of Blue Gem, proposing to adjust the partnership’s 1982 and 1983 returns. On September 20, 1988, the Brookhaven Service Center received a protest from 7201 Associates contesting the proposed adjustments in the 60-day letter and requesting an Appeals conference. Mr. Leffert filed the protest on behalf of 7201Page: 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