Free Answer - District Court of Federal Claims - federal

AP.R-21-2006 08: 54 CANANDA I GUA BRANDS Case 1:07-cv-00764-ECH Document 10-2

Internal. Revenue Service .
P.O. Box 66781 Stop 4020 STL .

716 Filed 03/03/2008 Notice 200D- Case

218 2160 Page 1

of P.02/12 11

Department of the Treasury
Refer To: Penny SchupmaM

Att; Penny Schupmann St. Louis, MO 63166

Name of Partnership: R,R,M & C Group, L.P.

Partnersip Identing Numbe 43-1936516
Date: Apr1113.200

Tax Year Ended: December 31, 2002
Date FPAA Mailed to the Tax Mattens Parter: 13. 2006 April

R,R,M & C Group, L.P. Attn: The Tax Maters Partner c/o Constellation Brands, Inc.

370 Woodclif Drie Suite 300
Fairprt, NY 14460

Person to Contact Penny Schupmann
Employee Number: 43-15317

Contact Telephone Number: 314-12..7
(not a toll fre number)
Contact Hours: 8:00 AM to 4:30 PM

NOTICE OF FIAL PARTNRSHI ADMIISTRTI ADJUSTMENT
The law reuires us to send a Notice of Final Partnership Administrative Adjustment (FPAA) to the partnership

named above, for the ta year shown above, and to each parter who is entitled to receive this notic.
We are proposing adjustments to the partnership Items of the partership and the tax year shown above. We will send the examination report outlinIng these adjustments to the Tax Matters Partner (TMP) of the partership. (The TMP is the partner designated by the partership to deal with the IRS.) He/she is also authorized to act for the parters who are not entitled to receive this notice. Any parter who wants a copy of the examination report should request it frm the TMP. If the TMP is unable to provide you with a copy of the examinatin report. please contlct the person named in the heading of this letter.
Taxable Years Ending Before August 6,1997:
The adjustments to the partnerShip Items reported on the partership tax return may caUSe an increase or decrease to the ta liabilty on your individual return. Form 870-P, Agreement to Assessment and Collection of Deficiency in Tax fo Partnership Adjustments, is a summary of the proposed adjustments to the partership return. You can compute your share of the proposed adjustments by multiplying each adjustéd partership item by your percentage interest for that partnership item.

Taxable Years Ending After August 5,1997:

The adjustments to the partnership items reported on the parterShip ta return may cause an increase or decrease in the ta liabilty on your Individual retum. The adjustments may Include partership level determinations

regarding penalties and additions to tax that relate to adjustments to parterShip items. Form 870-PT, Agreement
for ParterShip Items and Partnership Level Determinations as to Penalties, AdditIons to Tax, and AdditIonal Amounts. is a summary of the proposed adjustments to the partnership return. You can compute your share of the proposed edjustments by multiplying each adjusted partnerShip item by your percentage interest for that
partership item.

-: GOVERNMENT '" ii EXHIBIT
~

!I
iE

Letter 1830 (DO) (Rev, 3-2001)

I

SANDS1794

AP.R-21-2006 08: 54 CANANDA I Document 10-2 Case 1:07-cv-00764-ECH GUA BRANDS You have three options available to you:

716 Page 2 of 11 Filed 03/03/2008 218 2160 P. 03/12

1. If you agree with thé adjustments:
Sign and return the enclosed Form 870-P/Form 87Q.PT. When you sign Form B70~P/Form 87o-PT. you are agreeing to pay any additional tax and interest resultng from the adjustments to the partership return. For tax years ending after August 5, 1997. you are also agreeing to any partnership level deteln.ination as to penaltes, additions to tax and additional amounts that relate to adjustments to partership items. if any. In addition. you are waiving your rights to participate In any administrative or jUdicial proceeding affecting partnership items and in partership level determinatIons as to penalties,
additions to tax and additional amounts that relate to adjustments to partnership items for the ta year in

question. This is a binding settement only if you sign and return Form 87o-P/Form 870~PT and we sign on behalf of the Commissioner of Internal Revenue Servce. When we sign the agreement form. the oneyear extension of the periOd of limitations on assessments Will begin under Internal Revenue Code section 6229(f). Once the agreement is signed by both parties. you may not file a claim to change the items in question or claim a refund/credit based on a readjustment.

Note: If you are the TMP of the partnership, see the section of this lettr entitled. .For the Tax Matters Partner of the Partnership".

2. .If you do not agl'e with the adjustments:
lf you are the TMP of the partership and want to contest the adjustments in court, you must file a petiton within 90 days from the date this letter. During this 90-ay penod, no other partner may file a petition for jUdicial review. You can file your petiion for readjustment of partnership items with:
1. the United States Tax Court;
2. the United States Court of Federal Claims; or

3. the Distrct Court of the United States. in the district of the partership's principal place of business.
A petition filed by the TMP precludes all other actions. If the TMP doesn't file a petition by the 90t day from the date the FPAA was mailed, any partner or any 5 percent group entitled to receive this notice may petiion one of these courts. A "5 percent group" includes any group of parters \No together have an interest offive percent or more in profits of the partnership. The petition must be filed after the 90th day, but on or before the 150th day from the date the FPAA was mailed to the TMP. If more that one petition is filed in Tax Court, the first petition wil go forward. All other petions (even those filed earlier in one of the other courts) wil be dismissed. If no one fies a petition in Tax Court. the first petition fied in one of the other courts wil go forward and subsequent petitions wil be dismissed.
Petitions fied with the United States Tax Court must be mailed to:

United State Tn Cour
400 Second Street NW
Washington, DC 20.217-

Attach a copy of this letter to the petition. The time in which you must file a petition wih the court is fixed by law and the court can't consider your case if your petition is filed late. If this letter Is addressed to both a husband and Wife and both want to petition the Tax Court both must sign the petition .or each must file a separate signed petiion.
When a partner (including each member of a 5 percent group thet files a petition) files a petition in either the appropriate District Court of the Court of Federal Claims, the partner filing the petition must deposit the amount that the partnets tax liabilty would be Increased if the treatment of the partnership

Letter 1830 (DO) (Rev. 3-2001)

SANDS1795

716 ÀPR-21-20Ø6~ I08:55~ maoe consistent With the treatment of partnership 2160 of 11 the . Case 1:07-cv-00764-ECH CANANDAIGUA BRANDS . Page 3 under Filed 03/03/2008 218 items P.04/12 ......... .... ..... ,.....11'"1 c;iUIIl Wtll Document 10-2
FPAA. If you reported the partnership items the way the partership reported them on Its return. you can . generally determine the amount to deposit by taking your pro rata share of the partnership adjustments into account In recomputing your tax. You must deposit the appropriate amount with the IRS on or before the day you file your petition.

3. If you do nothing:
If a ,petition for readjustment is not filed in any of the courts listed in this letter, the FPAA becomes final, and we WILL bil you for any additional tax plus interest that you may owe under the FPAA. You wil

not be permItted to contest the treatment of the partership items of the partnership under the FPM in
any refund claim or suit. The law allows the Servce to bil you 150 days from the mailng date of the FPAA to the TMP.
However, if a petiion is filed In the Tax Court. and the Tax Court upholds the adjustments in whole or

in part, we wil not bil you until the Tax Court decision is frnal.
You may wish to contact the TMP of the partership or your tax advisor to discuss this matter.
If you have any questions, please write to the person Whose name and address are shown in the heading of this letter. If you write, attch a copy of this letter to help identif your account. Also. include your telephone number and the most convenient time for us to call you in case we need additional information.

If you prefer, you may call the IRS contact person at the telephone number shown in the heading Of this letter. If this number is outside your local callng area, there wil be a long distance charge to you.
Thank you for your cooperation.

~~
Sincerely,

for Kevin Harrs. Technical Servces Territory Manager

Enclosures:
Form 870-P/Form 870-PT

Copy of this letter

Letter 1830 (DO) (Rov. 3-2001)

SANDS1796

716 2160 ÀPR-21-2006 08: 55 Case 1:07-cv-00764-ECH ....u. .Uiini 10-2 --CANANDA I GUA BRANDS 03/03/2008 218~ 4 of 11 ---- Document r.tU~.IFiled ..PAR.A.n~u. vr .lHJ . Ti'rPage P. 05/12
If you are the .Tax Matters Partner (TMP), you are entitled to make an agreement to bind nonnotice partners to the treatment of the partnership items as shown on the enclosed schedule of adjustments. You must add the following statement above the signature blocks on the Form

8704P or Form 870-PT:
"The undersigned Tax Matters Partner is signing this offer on behalf of himself (herself and all other partners whom he (she) has the authority to bind; a final agreement resulting from the

co-signature. of the Commissioner of Internal Revenue wil be binding on all such other
partners. "

all partners. l
shown in the heading

As the TMP, you may submit a petition, as described above for the partnership on behalf of

If you have any questions, you can call the IRS contact person at the telephone number

of this letter. Thank you for your cooperation.

Lettor 1830 (DO) (Rev. 3-2001)

SANDS1797

. _..., w. .. , .

716 55 .._... Document ~1Il- Filed 03/03/2008 L 2160 P.06/12 I P?R-21-2006 1:07-cv-00764-ECH .... . u""iia' GUA1Lt:1I:: c-na t"artners 218eve 5 of 11 Case 08'-g- - -. CANANDA I 10-2 BRANDS h' ipPage . -

(0812001

Determinations as to Penalties, Additions to Tax, and Additional

IN REPLY REFER TO:

Taxp~yer(&) name(s). addrøss and zip COd,,;

Amounts
Name of Partership:
R,R,M & C Group, LP.

P.nny Sciipm.nn
Tax Year(s) Endei

R,R,M & C Group, L.P. Attn: The Tax Matters Partner

clo Constellation Brands, Inc. 370 Woodcliff Drive Suite 300 Fairport, Ny 1440
Taxpayer Identifying Number: 43-1936516

12/31/2002

Taxpayer Identifying Number:

43-1936516
Name of Tax Mattens Parter:

Ofter of Agreement to Partnership Items aDd Partnership Level Determinations as to Penalties, Additions to Tax, and Additional Amounts
Waiver of Restrictions on Assessment for Partnership Items, Penalties, Additions to Tax, and Additional Amounts
Under sections 6224(c) and 7121 of the Internal Revenue Code (IRe) of i 986, the Cornmissioner of the Intemal Revenue Service and the undersigned taxpayer(s) agree to the determination of partnership items
and partership Jevel determinations as to penaltes, additions to tax, and additionai amounts that relate to adjustments to partnership items as shown on the attched schedule of adjustments.
The undersigned taxpayer(s). in accordance with IRC sections 6224(b) and 6213(d). also waive the restrictions provided by IRe sections 6225(a) and 6213(a) and consent to the assessment and collection of
&

any deficiency attbutable to partnership items, penalties, additions to tax, and additional amounts that relate
to partership items, as determined in this agreement; plus any interest provided by law.
This agreement is conditional and wil not become effective or final until this agreement form is returned to the Commissioner and is signed on his ór het behalf. The one-year extension of the period of limitations on assessments under IRC section 6229(f) will not begin to run until the date the Cornmissioners representative signs this form on the Commissioner's behalf. If this is a partal agreement, tne period of limitations for asSessing any tax attibutable to the settled items shall be determined as if this agreement had not been entered into.
If this part of this agreement form is signed for the Commissioner, the treatment of partnership items and partership level determinations as to penalties, additions lo tax and additional amounts that relate to adjustments to partership items under this agreement will not be reopened in absence of fraud, malfeasance, or misrepresentation of fact. In addition, no claim for an adjustment of partnership items, refund

or credit based on any change in the treatment of partership items or partnership level determinations as to
penalties, additions to tax and additional amounts may be fied or prosecuted.
Signature of taxpayer
Date Signiid

Signaturø of taxpayer

Date Signed

"By (SIgnature and tiUe)

Date Signed

FOR
INTERNAL

Datø accøpt9d for Commissioner

Signature
Title

REVENUE
USE ONLY

Ofce

Cat No. 57315A

ww.jrs.a~ (See Instructions For Signing Agreement)

Form B70-PT (8/2004)

SANDS1798

APR-21-2Ø06 08:55 CANANDA I GUA BRANDS Case 1:07-cv-00764-ECH Document 10-2

716 Page 6 P.07/12 Filed 03/03/2008 218 2160 of 11

INSTRUCTIONS FOR SIGNING FORM 870~PT
1. If a JOINT RETURN OF A HUSBAND AND WIFE was filed and both spouses intend to agree, both Spouses sliould sign Form a70-PT. One spouse may sign as agent for the other if acting Under a power of attorney, which, If not previously filed, must accompany this form. The IRS may accpt the signature of only one spouse at Its discretion. However, the agreement wil only be bInding on the I.

. signing spouse. .
signature and title of the offcer authorized to sign Form a70-PT.

2. If the taxpayer is a corporation, the waiver must be signed wit the corporate name followed by the
3. Your attorney or agent may sign for you if this action is specIfically authorized by a power of attorney, which if not previously flied, must accompany this form.

4. If this offer is signed by a trust, the agreement must be signed with the trst name, followed by the sIgnature and title of the person authoried to sign on behalf of the trust.
5. If this offer is with respect to. the tax liabilit for the consolidated retum year, the agreement should be signed in the name of the common parent of the consolidated group for the consolidated return year. The common parent corporation signs the agreement in its own name. The sIgnature and title

of a current offcer of the common parent corporation, who is authorized to bind the corporation,
should be displayed in the signature block.
6. If

the Tax Matters Parter signs this offer, please include the t!e with the signatUre.

7. If this offer Is signed by a Tax Matters Partner that is a Subsidiary corporation, then an offcer authorized to sign this agreement for the year(s) Indicated o.n the form must sign for the parent
corporation. An authorized offcer for the subsidiary corporation should also sign if

the Tax Matters Partner is binding non-notice parters under the agree.ment. See Treas. Reg. 1.1502-77(a)(3)(v).

RGS Versio 6.20.00

WW.Ir.go

(See Instructions for SIgnIng Agrement)

Form 870.pr (Rv. 8-20)

SANDS1799

APR-21-2006 08: 56 CANANDAI GUA BRANDS Case 1:07-cv-00764-ECH Document 10-2

716 Page 7 of 11 Filed 03/03/2008 218 2160 P. 08/12

DcøSr\enl of th T_ui . Inloml Revenue 6e

AGREEMENT FOR PARTNERSHIP ITEMS AND PARTNERSHIP LEVL DETERMINATION AS TO PENAL nES, ADOITONS TO TAX, AND
ADDITIONAL AMOUNTS

SCHEDULE OF ADJUSTMENTS
NAME OF PARTNERSHIP:

R. R, M & C GrOup, LP
TAXPAYER IDENTIFYING NUMBER: 43-1931SJ6

TAX YEAR(S) ENDED
12111200

DETAIL OF ADJUSTMENTS TO OROINARY INCOME:

a.
b.
c.

d.

8.
f.

g.

Total Adjustments to OrdInary Income.
Oter AdJu8tmenu
8. Por Income (10&) divdends

(1) Adjustmnt

(2) As report

(3) Corrct
b. Portolio InCO (ioll) net Sllrt-ter gain (los)

(1) Adjustmnt
(2) As reported

(5,348,730.00)

5,348,730.00
0.00

(3) Corectec

Remark:
It js deteined that the acurcy-relate penalties provided by IRe 6662(a) and 6662() apply to the enti amount of any
underayment ofiax attbutable to adjustments of

the pannenhip items ofR. R, M & C Group, L.P. for the taable yea endig

Decembe 3 i, 2002. TIie accompanying Expl.iition of Adjusticnts to Parership Items and Parerhip-Ievel Determinations is

hereby incoiponn:ed by reference.

RGS Ven; 6.20.00

WI .irs.gov

For 87D-

SANDS1800

ÀPR-21-2006 08:56 CANANDA I GUA BRANDS Case 1:07-cv-00764-ECH Document 10-2
Name of Partership: R, R, M & C Group, L.P

Filed 03/03/2008

716 218 2160 P. 09/12
Page 8 of 11
Page
of

." Form 87()-PT, Other Adjustmen~Continued)

Taxpayer Identiing Number. 43-1936516

Tax Year(s) Ended
c. 09du~ons related tc portolo Inme
(1) Adjusbnént
(2) As reported

(3) COl'ct
d. Invøstnt Income InclUded In POrtli incoma

(1) Adju6tent (2) As report (3) Corrcted
e. Pertol$' Capil AccunIG. ScdUle M-2, line 1

(1) Adjustent
(2) A$ reportd

(3) Corrcted
f. Neilncx (Ioss)per bo, Sdedule M-2. line 3

(1) Adjustent
(2) As reported

(3) Corrct
g. Otlt InCles, Scldule M-2, One 4

(1) Adjustmnt

(2) As report
(3) COl'cted
h. Otr DeCfOBGIi. Scdule M-2. lie 7

(1) Adjustmnt (2) A, reportd (3) Corrcted
i. Parters Callal AcUnts. ScdlU9 L, line 21

(1) Adjustmt
(2) As reported

(3) Corr
j. Dlsut of ITney - CsGh and Msrketable SecurlUes

(1) Adjustmnt
(2) A, reported

(3) Corrcted
(1) Adjustment

(2) As reported (3) Correced (1) Adjustmnt
(2) As reported

(3) Corr
RGS Ver&/on 6.20.00

ww.lrs.1l0V

For 870-PT (contnue)

SANDS1801

Case 1:07-cv-00764-ECH

Document 10-2

716 Page 9 of 11 Filed 03/03/2008 218 2160 P. 10/12

CAPIT At ACCOUNS $75 694 09 $7~ 694 095 $-It is deteried tht each paror orR. R. M & C GroUp, LP. (herinafer refeIed to as the "Parerhip"), ha a

~eginng net contruton and net capita account balane of zero with the rost tht the aggregate contrbution an
capita àecount balance of the parer as of

$75,694,095 as clai on the Parershi 's retu

th beging of

the Piierhip's taxble ye 2002 is $4 inte of

A RlSONS FOR TmS DETERMATION CLUDE TIl FOLLOWIG
i Unde 1.R.C. § 752(a) and (b), th short sae¡obligations purorty assumed by the P8Iershi du

the taable ea 200 i ar arrsm liabiles
2 Und Tre8.. Reg. § i. 752-6, if the short sal, obligations purortedy assumed by the hrrnersp durg
the taable yea 2001 ar not I.R.C. § 752(a) and (b) libilties, then they are non-I.R.C. § 752 liabilties
under Tre. Reg. § 1.752.., the assumption of

in the Paner . b the amouni of the shortwhich decrees the contbutg Parer' outside bases sale: oc. 3 Under Tre. Reg. § 1.70 i -2, the puroned contnbutions by the par to th ParetWp du the

taable ye 200 i are diegared for feder iiconie Ia puros to produce ta conseqnces to th
parer tht ar consisnt with the economic consequees of an investent in the Parenp becae th Parership wa fonied and the contrutions wer madc: to reduce SUbstatially the preset value of
the arrs' a ate ta libil in a maer innsisnt with the inte ofSubc te Ie.
4 Under the economic substace dotre, the paer' purrt contrbutions of

Parerp durg th table )' 200 1 ar diregarded, an therfor the pmprted Parer accoun to brokerge of the

the

Parersp are trea for fed inome ta PUJSC8 al if thy diectly held the short sae positions in

those accoun. B TAX ITEMS OF THE PARTNERS THT MAYBE AFFECTED INCLUDE THE FOLLOWlG
i The parers' respeve outside bases in the Parers equa $.. as of

Pare . '5 Iaable ea 2002.
__ .~ ~1.; :. ~ .

the beging of

th

n IDENTITY OF PARTNERS

,.I

It is de1eed tht as of the begi of the taable ye 2002 the lite parenhip interets in the Parrsp purortedly held by vaous, so-ed "chatable remader UD-tr" are owned for fedral income ta purses by
th re ective ton of those trts con to the Parershi 's reru for the taable ea 2002.

lI:,j

A REASONS FOR THS DETERATION INCLUDE TH FOUOWIG 1 For feder income t. pwposes, the onginlimte parer of the Parership, not thei respective
chatale remaider un-trsts, are the 8ubstiti owner of

Parerhi thou Out the taable ea 2002.
i Under I.R.C. §§ 703 an 704. ta items of

the lited parers interests oftb

B TAX ITMS OF THE PARTNi:RS TIT MAY BE AFFECT INCLUDE THE FOLLOWIG
the Parership alocable to the lite parership interests

purortedly held by the chatable remainder ll-trst ar allocted a.ong th orgilite Par in accordace with their on inal rcenta e inier in the Parer . .

m CASU DISTRIUTION ~ $75 933 078 $75 933 078
. . .s- _
, .

,M lt

It is deterned thi dug the taable yea 2002 the Piiership ditrbute ca in the aggrgate amount of $75,933,078 to the parers in accorde with their respve percentage intets in the Parers, as reorted on the Piierhi ' S rttu for tht cu.

A REASONS FOR THS DETERMATION lNCLlJE THE FOLLOWIG
i No iijustment is made to the ca distnbution reportd On the Parershi's .retu. for the table yea

2002.

B TAX ITEMS OF THE PARTNRS TlIT MAY BE AFCTED lNCLtmE TH FOLLOWIG i Under I.R.C. § 731, a parer regns gaii On the Teipt of a ca ditrbution in exces of the parer's outsde bass in the Parhip.

SANDS1802

".

Case 1:07-cv-00764-ECH

Document 10-2

716 Page 10 P.11/12 Filed 03/03/2008 218 2160 of 11

IV CAPITAL GAIS AN LOSSES ($5348,730 $S 48730 $_0It is determed tht durng the tale year 2002 the Parerp ha net short-ter capita gain of $-0- intea of net
shrt-ter Ca ita ai of$5~348,730 as rt On the Parer¡ . 's retu
. '2.:!

A lUASONS FOR mis DETERMINATION INCLUDE TH FOLLOWIG
i On Schede D of

capita gain attbotable to a distrbution of cash under I.RC. § 731, whe iuy such gai should be

the Piuership's retu for the table year 2002, the Parerhi imroly rertd

Teeo . ed and ortd b the arer, not the Pareihi . B TAX ITES OF TH PARTNRS 'fT MAY BE AFFECTE INCLUDE TIl FOLLOWIG i Und J.R.c. §§ 731 and 741, 8 parer recognes capita gai on a.cash distrbutioii by the Piierhip to
the exteiit th amount distributed exceed the arer's ta basis in the Par

V ACCURCY-RELATED PENALT!ES It is determed tht the 40% accucy-related penaty provided by I.Re. § 6662 (h) or, altetively. the 20% 8ceuny-related penaty provide by I.Re. § 6662(8) applies to the enti amoun of any unde¡yment of ta
attbutale to the SdU8tJents of arers items of the Parersh for the taable ea 2002.

A REONS FOR TilS DETERMATION INCLUDE THE FOLLOWIG
i Th amount of iuy unClsymeit of

6662 ).
2 Altetively, the entie amun of any underpaymont of

ta is attbutable to a gr valUtion mistatement uner.J.R.C. §
ta is attbutble to a substal valUltion

misstatemeit unde I.Re. § 6662 e .

3 Altevely, the enti amount of any underpayment of ta is attbutable to negligence or digar of

rues Or ations Under I.Re. ~§ 6662 a , 6662 1 , and 6662 c .
.4 Alternatively, the entie amount of

ta is attbutable to a substti untatement B TAX ITEMS OF TH PARTNERS THT 6662 2 , an 6662 d). INCLUDE THE FOLLOWIG MAY BE AFFECTE
of income ta \Jder I.Re. § 6662 a). an unrpayment of i Unde I.Re. § 6221, penalties determed in a parership proeed ar

attbutale to parerhip item and affected items subject to defens tht may be asserted by a parr in

applied to w:ayient

an action for refund afer assessment and a ont

SANDS1803

Case 1:07-cv-00764-ECH Document 10-2 Filed 03/03/2008 218 2160 of 11 716 Page 11 P. 12/12 CANANDR I GUA BRANDS ~PR-21-2006 08:58 Partnership Name: R. R, M & C Group, L.P.
Tax Year: December

31, 2002 EIN: 43-1936516

Infomiation Reoardina Additions to Tax (Penalties) and Affected Items

The Internal Revenue Code provides, in appropriate cases, for the application of

a,?curacy related penalties under Intemal Revenue Code Section 6662. which include,
in part, 'penalties for negligence or disregard of rules or regulations, substantial understatement of income taxi and substantial valuation misstatements.

For partership taxable years ending after August 5, 1997. penalties are determined at the partnership level and may be agreed to as part of the partnership proceeding. A
court wil have jurisdiction over partnership level penalties raised in a Final Partnership

Administrtive Adjustment petition for a partnership taxable year ending after August ~, 1997. Any partner level defense to partnership level penalty determinations, however,
may only be raised through refund claims following the assessment and collection of such penalties.
For all partnership taxable years, other items affected by partnership adjustments, "affected items," may also be separately determined and assessed after the outcome of the partnership proceedIng. Upon the completion of the partnership proceeding or the executon of a Form 870-PT, you may be sent an examination report and/or a statutory notIce of deficiency asserting affected items.

Please note: This Is an information item only, and is not part of the notice of Final Partnership Administrative Adjustment.

SANDS1804
TOTAL P.12