Estate of Donald H. Ray, Deceased, Patricia G. Ray, Independent Executrix, and Patricia G. Ray - Page 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                    
                    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                       
                    Once this settlement is accepted for the                          
               Commissioner, the service center will compute your tax                 
               liability and send you a bill for any additional                       
                    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