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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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