7
Court or a Federal district court where the
partnership's principal place of business is located.
This notice will be mailed to you if we have not heard
from you within 30 days as we will assume you do not
agree with the settlement. If penalties have been
asserted, they will not be included in the notice but
will be included in a separate report which will be
mailed to you after the partnership proceedings are
concluded.
If you wish to accept this settlement as explained
above, the signed agreement form with the attached
schedule of adjustments must be returned within 30 days
from the date of this letter. If a joint return was
filed, both spouses must sign the form (see
instructions on the form). The adjustments shown on
the enclosed agreement form are partnership
adjustments; you may determine your share of these
adjustments by multiplying your percentage of
partnership profit of [sic] loss times the total
adjustments.
Once this settlement is accepted for the
Commissioner, the service center will compute your tax
liability and send you a bill for any additional
amounts.
Please contact the person whose name and number are
shown above if you have any questions regarding this
settlement offer.
A copy of the Form 870-L(AD), parts I and II, is attached to this
opinion as an Appendix.
Breese reviewed the Palka letter, but it did not make sense
to him at the time, so Breese contacted Redding and asked "what
was going on." In a letter dated April 1, 1991, from Redding to
Balboni, Redding highlighted what he perceived to be inaccuracies
in the Palka letter, including the statement that, if the
partners do not agree to the settlement of the partnership items
within 30 days, an FPAA will be issued. When the Palka letter
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Last modified: May 25, 2011