Wayne Caldwell Escrow Partnership, Roy Dimon, John and Mary Schuenemann, Joseph and Louise O'Neal, Charles and Lovetta Niven, Chalton and Cynthia Thomas, Partners Other Than the Tax Matters Partner - Page 20

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                 Attached to Mr. Denny's letter is a copy of the letter               
             Mr. Caldwell had sent to Mr. Norstrud, quoted above.  The                
             date of Mr. Denny's letter, June 5, 1991, is 128 days after              
             the date on which respondent issued the notice of FPAA,                  
             January 28, 1991.                                                        
                 By letter dated June 13, 1991, Mr. Norstrud responded                
             to Mr. Denny.  Mr. Norstrud's letter states as follows:                  

                 Dear Mr. Denny:                                                      
                       In response to your letter dated June 5, 1991, the             
                 partnership referenced (Wayne H. Caldwell Escrow) has had a          
                 final determination made on the case.  The FPAA (final part-         
                 nership administrative adjustment) has been issued.  The tax         
                 matters partner has 90 days from the issuance date of the FPAA       
                 to file a petition with the Tax Court, District Court or Court       
                 of Claims if the proposed adjustments are not agreed to.  If no      
                 petition is filed within the first 90 days the notice partners       
                 then have 60 days in which to file a petition with one of the        
                 Courts.  If no petition is filed the case will be defaulted 150      
                 days after issuance of the FPAA.  At this time the processes         
                 will begin to have any applicable adjustments made to the            
                 partners [sic] returns.                                              
                       If you have additional questions regarding the partner-        
                 ship return you should contact the tax matters partner,              
                 Mr. Caldwell.                                                        
                                                Sincerely,                            

                                                /s/ D.V. Norstrud                     
                                                Daniel V. Norstrud                    
                                                Appeals Officer                       

                 Another partner, Mr. Gene A. Nickerson, also wrote                   
             to respondent in response to the notice of FPAA.                         








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