Laurence L. and Patricia Jacobs - Page 25




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          the limited partners on August 14, 1995, it was necessary to wait           
          several months to see how many partners would accept the offer              
          before respondent could send FPAA's to the limited partners who             
          rejected the settlement.  At that point, after the settlement               
          letters were mailed, the speed at which the matter was to be                
          closed was up to the partners.  The Geises never signed a Form              
          870-P(AD), and respondent did not receive the Jacobses' Form 870-           
          P(AD) until July 11, 1996.  From May until July 1996, when                  
          respondent sent the FPAA's to petitioners, Appeals Officer                  
          Thurston prepared the documents to be included in the FPAA                  
          package.  On the basis of the foregoing, we conclude that there             
          were no errors or delays in the performance of ministerial acts             
          by respondent's officers or employees during that period.                   
          Accordingly, we uphold respondent's final determination not to              
          abate interest from April 22, 1994, through July 8, 1996.                   
               To reflect the foregoing,                                              

                                             Decisions will be entered                
                                        abating interest for the period               
                                        of time stated herein.                        














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