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containing false and fraudulent items with the intent to evade
tax, the periods for assessment against him individually of tax
liabilities attributable to the partnership items are open
indefinitely. See sec. 6229(c)(1)(A). Therefore, it follows,
and we so hold, that the FPAAs were timely issued as to Hoyt
individually for the 1984, 1987, 1988, and 1989 returns.
To reflect the foregoing,
Appropriate decisions will be
entered.
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Last modified: November 10, 2007