4
had assigned Michael Goldbas (Goldbas) as the lead attorney on
that project. The project encompassed over 2,000 partners, and
Goldbas was responsible for the administration and litigation of
the Transpac project.
Respondent mailed the tax matters partners of Transpac
partnerships 1982-15 and 1982-21 Notices of Final Partnership
Administrative Adjustments that set forth adjustments determined
by respondent for the taxable years 1982, 1983, and 1984.
In a letter dated September 25, 1990 (September 25th
letter), respondent mailed Fensterheim a separate Settlement
Agreement for Partnership Adjustments and Affected Items (Form
870-L(AD)) for each Transpac partnership, 1982-1, 1982-15 and
1982-21. Relevant portions of the September 25th letter state:
In re: Settlement of Tax Matters
Relating to Transpac
Drilling Venture
Dear Transpac Investor:
You are probably aware that the Service has
developed a settlement proposal with respect to matters
relating to the disallowance of the losses (and
credits) you reported from your Transpac Drilling
Venture. The pending settlement offer is that you
concede the full disallowance of all reported
partnership losses (and credits) and the Government
will concede all penalty issues. The interest on the
tax deficiencies resulting from this settlement will
run at 120% of the prevailing rate pursuant to I.R.C. �
6621(c).
* * * * * * *
In order to process the above described settlement
you must complete the enclosed form 870-L(AD) * * * in
the following manner: First, complete the section * *
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