Estate of Donald H. Ray, Deceased, Patricia G. Ray, Independent Executrix, and Patricia G. Ray - Page 8

          was mailed, respondent had already issued an FPAA, and the TMP              
          for Valley Cable had already filed a petition in this Court.  In            
          a letter to Redding dated April 4, 1991, Balboni stated that the            
          Palka letter was computer generated, that it was incorrect, and             
          it should not have been sent in that form.  In that same letter             
          Balboni stated:                                                             
               In order to clear up any potential misunderstanding                    
               caused by the [Palka] letter in these cases, I am                      
               willing to write and send a letter to each of the                      
               partners of Valley Cable, Ltd., or their known                         
               representative, which clarifies the settlement offer                   
               and the deadline for its acceptance.                                   
               In an attempt to clarify the Palka letter, Balboni sent a              
          letter dated April 4, 1991 (Balboni letter), to the partners of             
          Valley Cable.  That letter also was sent to Redding as counsel              
          for Wilder.  The Balboni letter stated:                                     
               Dear Sir/Madam:                                                        
                    I am the attorney representing the government in                  
               the above-referenced cases.  Our records indicate that                 
               you are a partner in Valley Cable, Ltd.  It has just                   
               been brought to my attention that you have received a                  
               letter from the Austin Compliance Center which                         
               communicates an offer by the government to settle the                  
               above-referenced cases.  Because that "form" letter is                 
               not entirely correct, I am taking the unusual step of                  
               writing to you in an attempt to clarify the terms of                   
               the settlement and also to set the final deadline for                  
               accepting the offer.  If you are represented in this                   
               matter, please forward this letter to your                             
               representative at once.                                                
                    The "form" letter states that if you do not agree                 
               to the settlement offer within 30 days, a Notice of                    
               Final Partnership Administrative Adjustments will be                   
               issued.  This statement is incorrect because such a                    
               notice has already been issued for both the 1983 and                   
               1984 taxable years.  Both years are presently docketed                 

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