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 letterPage: 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