- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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