Rodney J. and Noreen E. Blonien - Page 13




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               The extensions were necessary as all the data needed to                
               file a complete and accurate return was not available                  
               at the time of the original due dates.  In particular a                
               New York based law partnership, (Finley, Kumble and                    
               Wagner--13-1694664) in which Mr. Blonien was a partner.                
               This particular partnership filed for bankruptcy in                    
               1988 and has been in audit by the Internal Revenue                     
               Service for years.  Mr. Blonien has been involved with                 
               the various lawsuits and audits from 1988 to the                       
               present, (last correspondence from the service                         
               regarding this partnership is dated December 22, 1994).                
               This partnership alone made it impossible to file his                  
               returns without additional time allowed by the                         
               extensions.  [Emphasis added.]                                         
               On May 10, 1996, respondent appointed Marshall Manley to be            
          the tax matters partner (TMP) for Finley Kumble because he was              
          the Finley Kumble partner with the largest partnership share.  On           
          June 20, 1996, Marshall Manley, as TMP of Finley Kumble, signed a           
          Form 872-P, Consent to Extend the Time to Assess Tax Attributable           
          to Items of a Partnership, by which the period to assess the                
          Finley Kumble partners for partnership items for the calendar               
          year 1992 was extended to December 31, 1997.  On May 29, 1997,              
          Mr. Manley, as TMP of Finley Kumble, signed a second Form 872-P,            
          extending the assessment period to December 31, 1998.                       
          Petitioners were aware that respondent was examining Finley                 
          Kumble’s partnership returns.                                               
               On August 10, 1998, respondent issued a notice of final                
          partnership administrative adjustment (FPAA) for Finley Kumble to           
          Marshall Manley, TMP, for the calendar year 1992.  No petition              
          was timely filed with respect to the FPAA.                                  







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