Estate of Donald H. Ray, Deceased, Patricia G. Ray, Independent Executrix, and Patricia G. Ray - Page 6

                                          6                                           
          with a copy of the Form 870-L(AD).  The relevant portion of the             
          Palka letter states:                                                        
               Dear Mr. Wilder:                                                       
                    The Appeals Office has completed settlement                       
               negotiations on the * * * [Valley Cable partnership]                   
               and the results of those negotiations are shown on the                 
               enclosed Form 870-L(AD) and attached schedule of                       
               adjustments.  We believe this settlement is a fair and                 
               equitable resolution of the adjustments.                               
                    As a partner in the partnership, you have the                     
               right to participate in the settlement.  You may either                
               agree to the settlement of both the penalties and the                  
               partnership items or agree to the settlement of only                   
               the partnership items. (Penalties include interest                     
               under section 6621(c) of the Internal Revenue Code.)                   
               The following instructions explain how you should sign                 
               the settlement agreement (Form 870-L(AD) to show the                   
               extent of your agreement:                                              
                         If you agree to both the partnership                         
                    adjustments and penalties, please sign Parts                      
                    I and II of Form 870-L(AD).  This will allow                      
                    us to close your case with finality on both                       
                    the penalty and partnership items.                                
                         If you agree only to the settlement of                       
                    the partnership items, please sign Part I of                      
                    Form 870-L(AD).  This will allow us to close                      
                    your case with finality for the partnership                       
                    items only and will leave open any penalty                        
                    issues.  A separate report on the penalties                       
                    will be mailed to you later which will allow                      
                    you to either file a petition to the United                       
                    States Tax Court or to file a protest                             
                    requesting further Appeals consideration.                         
                    However, it is unlikely that the offer shown                      
                    in the agreement will be changed unless you                       
                    are able to submit facts not previously                           
                    considered by the Appeals office.                                 
                    If you do not agree to the settlement of the                      
               partnership items, a notice of Final Partnership                       
               Administrative Adjustment will be mailed to you on                     
               these items.  This notice will allow you to file a                     
               petition with the United States Tax Court, the Claims                  




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011