- 18 - March 14, 1990, Through October 22, 1995 The record discloses only sporadic and inattentive IRS activity in the Blue Gem case with respect to the period from March 14, 1990, through October 22, 1995. During this 5-year period, Appeals Officer Koniarski appears to have worked on the Blue Gem case only intermittently for brief amounts of time. Indeed, in his testimony at trial, Mr. Koniarski acknowledged that no further factual development of the case was needed during this period because all necessary factual development had been completed during the revenue agent’s earlier examination. The record further reveals that neither the Blue Gem TMP nor any of the notice partners except 7201 Associates chose to participate in the administrative appeal of the Blue Gem case. As Appeals Officer Koniarski stated in his supporting statement recommending issuance of FPAA’s with respect to Blue Gem’s 1982 and 1983 taxable years, the Blue Gem TMP never filed any protest; the only protest filed was Mr. Leffert’s protest letter on behalf of 7201 Associates. In his testimony, Appeals Officer Koniarski claimed the Blue Gem TMP had been uncooperative, and Mr. Koniarski attributed his inability to close out and conclude the Blue Gem case sooner, in part, to this lack of cooperation by the Blue Gem TMP. The Blue Gem TMP had postponed the Appeals conference originally scheduled by Mr. Koniarski. According to Mr. Koniarski, his subsequentPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011