Charles Deverna - Page 3

                                        - 3 -                                         
          partnerships were selected for litigation of the Swanton coal               
          programs in the Tax Court.  The remaining 20 TEFRA partnerships             
          agreed to be bound by the outcome of the test cases.  Matthew               
          D. Lerner (Lerner) of Zapruder & Odell represented 17 of the                
          TEFRA partnerships associated with Swanton, but did not represent           
          Manhattan Associates.  Lerner agreed to act for Manhattan                   
          Associates in a limited capacity in reviewing and signing                   
          decision documents and Forms 906, Closing Agreement on Final                
          Determination Covering Specific Matters.                                    
               On May 18, 1984, the Internal Revenue Service (IRS) sent a             
          letter to petitioner to notify him that Manhattan Associates was            
          selected for examination (notice).  The notice stated that the              
          IRS was not required to notify partners individually of                     
          conferences or other events during the TEFRA proceeding.  The               
          notice further stated that the TMP was “responsible for notifying           
          partners of the more important events during the proceeding, but            
          the results of the proceeding generally apply to all partners               
          even if the tax matters partner does not provide that                       
          information.”  The IRS and the TMP were unable to reach a                   
          settlement for Manhattan Associates.                                        
               On August 3, 1990, the IRS sent to Manhattan Associates and            
          Brown a Notice of Final Partnership Adjustment (FPAA).  On                  
          August 20, 1990, the IRS sent to petitioner an FPAA.                        








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011