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your return remains open for any adjustment resulting
from the examination of Agri-Venture Fund.
By three letters dated June 25, 2002, respondent issued
Forms 4549A, Income Tax Examination Changes, to petitioner
concerning his 1984, 1985, and 1986 tax years. The Forms 4549A
showed increases in tax of $12,960.52 for 1984, $20,249.02 for
1985, and $15,109.01 for 1986. The adjustments shown in the
Forms 4549A all resulted from differences between the amounts of
AMCOR partnership losses petitioner reported on his 1984, 1985,
and 1986 tax returns and the amounts of losses ultimately allowed
to those partnerships at the close of partnership-level
litigation in this Court.
On or about July 15, 2002, petitioner mailed to respondent
three executed Forms 4549A and checks for the amounts of the
increases in tax shown on the Forms 4549A. On July 22, 2002,
respondent posted petitioner’s payments towards his deficiencies
and assessed additional taxes in the amounts paid. Respondent
simultaneously assessed interest for each year.
On November 1, 2002, petitioner submitted three Forms 843,
Claim for Refund and Request for Abatement, pertaining to his
1984, 1985, and 1986 taxable years. On his Forms 843, petitioner
requested interest abatement with regard to interest that accrued
on his 1984, 1985, and 1986 deficiencies during and after May
1988.
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