5 Southern Cable. Respondent assigned Peter Palka (Palka) as the project appeals officer and Albert Balboni (Balboni) as the project attorney on Southern Cable. Thomas E. Redding (Redding) was a taxpayer representative in the Southern Cable project, and he is also counsel for petitioners in these cases. On March 16, 1987, respondent issued to Valley Cable a Notice of Final Partnership Administrative Adjustment (FPAA) for the taxable year 1983, and on May 9, 1988, respondent issued to Valley Cable an FPAA for the taxable year 1984. After learning that respondent was challenging the tax deductions claimed by Valley Cable, Breese took the necessary steps to include RDB in a "group" formed to challenge respondent's determinations. Redding was counsel for that group. Victor M. Wilder (Wilder), Tax Matters Partner (TMP) for Valley Cable, timely filed petitions for readjustment of partnership items under section 6226 with respect to Valley Cable's 1983 and 1984 taxable years. In a letter dated March 25, 1991 (Palka letter), Palka mailed to Wilder a Form 870-L(AD), Settlement Agreement for Partnership Adjustments and Affected Items (Form 870-L(AD)), with a corresponding schedule of adjustments for Valley Cable's taxable year 1983. A separate Palka letter sent to Mr. Wilder dated March 25, 1991, contained a Form 870-L(AD) and corresponding schedule of adjustments for Valley Cable's taxable year 1984. RDB also received a copy of the Palka letter alongPage: 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