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On May 14, 1990, respondent assessed penalties of $90,000
under section 6701 against Hoyt. Hoyt filed a refund claim in
July 1990. In November 1990, respondent’s counsel advised the
IRS that, in the light of the Bales opinion, it was unlikely that
imposition of the penalties ultimately would be sustained. The
IRS abated the $90,000 of section 6701 penalties in early 1991.
In October 1990, the IRS issued Hoyt a summons for the sheep
partnerships’ 1987 tax year. At the time, respondent was also
seeking documents to prepare for trials pending in this Court
regarding cattle partnerships’ 1980-86 taxable years. Hoyt
informed respondent that he was unable to simultaneously produce
documents for the docketed cattle cases and the sheep
partnerships’ 1987-90 taxable years.
Hoyt and the IRS executed Forms 872-P, Consent to Extend the
Time to Assess Tax Attributable to Items of a Partnership,
extending the period of limitations on assessments for certain
taxable years of RCR #2, RCR #3, RCR #4, RCR #5, and RCR 85-2.
Hoyt executed each of the extension agreements as TMP for the
various sheep partnerships. The partnership taxable year
involved, the date upon which the partnership return was deemed
filed, the date the original 3-year period for assessing a
deficiency would expire, the IRS extension form used, the date
upon which the IRS executed the form, and the date to which Hoyt
and the IRS (in the form) agreed to extend the period of
limitations were as follows:
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