-5-
3. The Start of Respondent’s Audit of Leatherstocking’s 1983
and 1984 Partnership Returns of Income
Leatherstocking filed a 1983 and a 1984 Form 1065, U.S.
Partnership Return of Income, on May 29, 1984, and April 22,
1985, respectively. In 1985, respondent selected the 1983 return
for audit and assigned the case to Jane Hursty (Hursty). Hursty
later notified Leatherstocking that its 1984 return also was
selected for audit. In late 1986 or early 1987, respondent
notified Leatherstocking’s limited partners that Leatherstocking
was being audited.
During respondent’s audit of Leatherstocking, respondent
received various consents (consents) to extend the periods of
limitation for the subject years.2 The consents were signed by
Steele in his capacity as Leatherstocking’s TMP or, in the case
of a consent signed on February 4, 1988, by Daniel Kornblatt
(Kornblatt) in his capacity as Leatherstocking’s attorney and
authorized representative. The relevant details of the consents
for 1983 were as follows:
Date signed Date signed Extended date
by Steele by respondent for assessment
Nov. 18, 1986 Nov. 24, 1986 Dec. 31, 1987
Aug. 12, 1987 Aug. 14, 1987 Dec. 31, 1988
July 7, 1988 Aug. 31, 1988 Dec. 31, 1989
Aug. 14, 1989 Sept. 8, 1989 Dec. 31, 1990
May 30, 1990 June 8, 1990 Dec. 31, 1991
2 Each consent was given by way of Form 872-P, Consent to
Extend the Time to Assess Tax Attributable to Items of a
Partnership.
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