Terry Nathan Norman - Page 13

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               In July 2005, respondent’s Appeals officer sent a letter to            
          the corporation as PTSI’s tax matters partner asking for                    
          information about petitioner and the partnership (the Appeals               
          officer’s letter).  The Appeals officer’s letter was sent to an             
          address in Grayslake, Illinois (the Grayslake address).  Paul               
          Stern, who appears to have been an officer and/or director of the           
          corporation,4 responded to the Appeals officer in an undated                
          letter (Mr. Stern’s letter).  Mr. Stern’s letter states:  (1)               
          PTSI experienced several years of financial difficulty beginning            
          in the mid-1990s; (2) as a result, PTSI was unable to make                  
          distributions to petitioner and ultimately ceased operations in             
          2004;5 (3) PTSI did not have an updated mailing address for                 
          petitioner and had been sending his Forms K-1 to an address in              
          Chicago, Illinois, which was the address PTSI had on file for               
          him; (4) the Forms K-1 that PTSI sent had not been returned as              
          undeliverable; (5) PTSI had changed its principal place of                  
          business to the Grayslake address at an unspecified date and                
          remained there until April 2004; and (6) the Grayslake address              
          was no longer used to conduct business.  Mr. Stern’s letter                 
          concludes by listing a contact address in Oak Creek, Wisconsin              


               4 Mr. Stern signed the agreement on behalf of the                      
          corporation.                                                                
               5 Neither Mr. Stern’s letter nor the remainder of the record           
          indicates what happened to PTSI’s assets after the partnership              
          ceased operations.                                                          




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