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 docketedPage: 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