River City Ranches #1 Ltd., Leon Shepard, Tax Matters Partner - Page 35

                                       - 20 -                                         
               The Examination Division examined many of the returns of the           
          cattle and sheep partnerships and their partners for the 1980               
          through 1986 taxable years.  During the Bales litigation, the               
          Examination Division obtained extensions from the partners in the           
          cattle partnerships to extend the period of limitations for                 
          assessing and collecting income tax liabilities for the 1980,               
          1981, and 1982 tax years.8  After obtaining the extensions, the             
          Examination Division temporarily suspended examination activity             
          with respect to those tax years.                                            
               In early 1989, the Examination Division resumed examining              
          and processing the individual returns filed by partners in the              
          cattle partnerships for the 1980, 1981, and 1982 tax years.                 
          Shortly thereafter, standard revenue agent reports for those                
          years were prepared that proposed to disallow all tax benefits              
          these partners had claimed from the cattle partnerships.                    
               From about 1988 through 1991, an Examination Division team             
          conducted partnership-level examinations of many of the returns             
          of the cattle and sheep partnerships for the 1983 through 1986              





               8  The unified partnership audit and litigation provisions             
          of secs. 6221-6233, are not applicable to the pre-1983 taxable              
          years of the cattle and sheep partnerships.  These provisions               
          were enacted as part of the Tax Equity & Fiscal Responsibility              
          Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324,             
          648, and are generally applicable to partnership taxable years              
          beginning after Sept. 3, 1982.                                              





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