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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.
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