5
* of the form entitled "Taxpayer(s) name(s), address
and zip code." * * *
* * * * * * *
Second, sign the form twice in the spaces entitled
"Signature of Taxpayer" and set forth the date you
signed the agreement. * * *
* * * * * * *
Please note that you are not obligated to accept
the above described settlement. After you have signed
and transmitted the enclosed forms, however, you will
not be able to retract your acceptance of the
settlement offer. * * *
* * * * * * *
After we receive the executed Form 870-L(AD) * * *
the form will be reviewed and executed by the Internal
Revenue Service. The settlement is not final until the
enclosed forms are signed by a representative of the
Internal Revenue Service.
The September 25th letter also set forth the address to which the
completed forms should be mailed.
The Form 870-L(AD) contains the following language: "the
undersigned offers to enter into a settlement agreement"; "This
offer is subject to acceptance for the Commissioner"; "Unless and
until it is accepted, it will have no force or effect"; "If this
offer is accepted for the Commissioner"; and "Date accepted for
Commissioner".
In November 1990 at Fensterheim's law offices, Fensterheim
met with Goldbas on a matter unrelated to these cases. When the
meeting ended, Fensterheim and Goldbas met privately to discuss
Fensterheim's Transpac partnerships. The two met for about 30
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