River City Ranches #1 Ltd., Jeffry Bergamyer, Tax Matters Partner - Page 19

                                       - 19 -                                         
               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:                                                

Page:  Previous  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  Next 

Last modified: November 10, 2007