Messing Up EIN Result in Limitless Gift Tax Statute.

I.R.C. Sec. 6501(c)(9) says that if a gift tax return is required to be filed and is not filed, the IRS can collect the gift tax (with interest) at any time - the statute of limitations never runs.  In this matter, the taxpayer Filed Form 709 to report the transfer of partnership interests in two partnerships.  The Form 709 did not identify one of the partnerships involved and did not adequately describe the method used to determine the fair market value of both partnership interests.  Also, the employer identification number (EIN) used on both Form 709 and the valuation of gifts statement attached to the Form 709 was missing a digit.  The IRS noted that the appraisals valued the land held by each partnership rather than the value of the partnership interests that were transferred.  In addition, the Form 709 used incorrect, abbreviated names for the partnerships.  Based on these facts, the IRS determined that the gifts had not been adequately disclosed for failure to sufficiently describe the transferred property.  F.A.A. 20152201F (May 29, 2015).