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On petitioner’s 1987 individual income tax return, he
claimed a $319 general business credit relating to SGE that he
carried forward from his 1985 income tax return.
D. Respondent’s Examination of SGE for 1985 and 1986
On December 17, 1987, respondent sent a notice of beginning
of administrative proceeding (NBAP) to Jay Hoyt, the TMP of SGE.
The notice informed the TMP that respondent was beginning an
examination of SGE for the 1985 and 1986 tax years.
On July 20, 1988, respondent sent an NBAP to petitioner
notifying him that an examination was beginning on SGE for the
1985 tax year. On September 12, 1988, respondent sent petitioner
an NBAP relating to SGE for the 1986 tax year.
On February 28, 1989, an examiner with the IRS signed Form
4665, Report Transmittal, and Form 4605-A, Examination Changes--
Partnerships, Fiduciaries, Small Business Corporations, and
Domestic International Sales Corporations. Both forms related to
the IRS’s examination of SGE for the 1985 tax year.
In the Report Transmittal, the examiner discussed the
difficulties encountered in obtaining SGE’s records from the TMP.
The examiner recommended issuing a notice of final partnership
administrative adjustment (FPAA) because the lack of adequate
records did not allow respondent to perform a normal examination,
and the parties were in complete disagreement over the issues.
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