-3- partners” and the second was on the line labeled “other deductions.” JTA identified both these items, in separate statements attached to its return, as “Health Insurance Premiums.” Nehrlich agrees with the Commissioner that the double reporting of the premiums was simply a mistake. The Commissioner audited JTA's 1995 partnership return using TEFRA audit procedures, not because one of the partners had designated himself the TMP and the partnership return had a checked box stating that TEFRA procedures would apply, but because the examiner noticed that JTA allocated one item--the $12,850 in health insurance premiums listed under “other deductions”--other than in equal thirds.2 The focus of the audit, though, was the value of JTA’s gift to the University of Iowa. The Commissioner concluded the software was worthless, and made a $6 million adjustment. At the end of the audit, in October 2000, the Commissioner sent Wypychowski a Notice of Final Partnership Administrative Adjustment (FPAA) by certified mail. The Commissioner alleges that he also mailed an FPAA to Nehrlich, and offers as evidence the first page of an FPAA and a certified mailing list showing Nehrlich’s name and address. However, he stipulated that he cannot prove Nehrlich received the FPAA, and Nehrlich claims that he did not. 2 Nehrlich was allocated $2405; Wypychowski, $3111; and Yee, $7334.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007