6 with a copy of the Form 870-L(AD). The relevant portion of the Palka letter states: Dear Mr. Wilder: The Appeals Office has completed settlement negotiations on the * * * [Valley Cable partnership] and the results of those negotiations are shown on the enclosed Form 870-L(AD) and attached schedule of adjustments. We believe this settlement is a fair and equitable resolution of the adjustments. As a partner in the partnership, you have the right to participate in the settlement. You may either agree to the settlement of both the penalties and the partnership items or agree to the settlement of only the partnership items. (Penalties include interest under section 6621(c) of the Internal Revenue Code.) The following instructions explain how you should sign the settlement agreement (Form 870-L(AD) to show the extent of your agreement: If you agree to both the partnership adjustments and penalties, please sign Parts I and II of Form 870-L(AD). This will allow us to close your case with finality on both the penalty and partnership items. If you agree only to the settlement of the partnership items, please sign Part I of Form 870-L(AD). This will allow us to close your case with finality for the partnership items only and will leave open any penalty issues. A separate report on the penalties will be mailed to you later which will allow you to either file a petition to the United States Tax Court or to file a protest requesting further Appeals consideration. However, it is unlikely that the offer shown in the agreement will be changed unless you are able to submit facts not previously considered by the Appeals office. If you do not agree to the settlement of the partnership items, a notice of Final Partnership Administrative Adjustment will be mailed to you on these items. This notice will allow you to file a petition with the United States Tax Court, the ClaimsPage: 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