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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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Last modified: May 25, 2011