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Revenue Service, the tax matters partners of various partnerships
labored under a conflict of interest and, thereby, were
disqualified from binding the partnerships by extending the
assessment period.” The motion stated further that
Leatherstocking’s tax matters partner (TMP), Robert L. Steele
(Steele), had been under investigation by the Commissioner’s
Criminal Investigation Division (CID). This Court allowed
petitioner to amend the petition on November 4, 1998, to
challenge the timeliness of the FPAAs. When the case was called
for trial, petitioner conceded all allegations of error initially
set forth in the petition and stated that he was henceforth
relying solely on the allegation that the FPAAs were issued
untimely.
We decide whether the periods of limitation for assessment
as to Leatherstocking’s limited partners remain open for the
subject years. We hold they do. Unless otherwise indicated,
section references are to the applicable versions of the Internal
Revenue Code.
FINDINGS OF FACT
1. Preface
Some facts were stipulated. We incorporate herein by this
reference the parties’ stipulations of facts and the exhibits
submitted therewith. We find the stipulated facts accordingly.
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