- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011