Estate of Donald H. Ray, Deceased, Patricia G. Ray, Independent Executrix, and Patricia G. Ray - Page 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 along              

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