-26-
Leatherstocking audit.7 Nor do we believe that respondent was
precluded from dealing with Steele as Leatherstocking’s TMP
simply because he was imprisoned.
In sum, we do not find on the basis of the record at hand
that respondent obtained any of the consents by impermissible
means or that Steele had a serious conflict of interest with the
Leatherstocking partners as to the Leatherstocking audit. We
hold that the periods of limitation remain open for the subject
years. We have considered all arguments by petitioner for a
contrary holding and find those arguments not discussed herein to
be without merit. Given petitioner’s concession of all of the
underlying adjustments in the FPAAs,
Decision will be entered
for respondent.
7 We also are mindful that the Government’s sentencing
memorandum in Steele’s criminal proceedings stated that Steele’s
“failing to report his Marcos income * * * [and the issues
relating to] the partnerships of Steele formed to market cattle
embryos were better left to the IRS civil audit.”
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