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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