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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 7201
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