10
As stated above, the government's offer to settle
the above-referenced cases, including the penalty
portion, will expire on May 6, 1991. This deadline
will not be extended. However, if a partner of Valley
Cable, Ltd. properly accepts the offer, by law you will
be entitled to what is known as consistent settlement
for a period of 60 days after the government executes
that partner's Form 870-L(AD).
I sincerely hope that this letter eliminates any
confusion which may have been caused by the "form"
letter. As I am the attorney for the government, I
expect that you will consult someone before accepting
my word for all of the above. If you have any
questions, however, please contact the undersigned
* * *.
When Breese received the Balboni letter, he still was overseeing
RDB's investment activities.
The partners of RDB met with William Podsednik, Jr.
(Podsednik), a certified public accountant who had advised them
on various matters since 1988, to discuss what options were
available and whether to accept respondent's proposal. RDB,
through its partners, decided to "accept" respondent's proposal.
Mrs. Ray, acting on behalf of RDB, executed the Form 870-L(AD) on
May 2, 1991. Mrs. Ray executed the Form 870-L(AD) because she
held a majority interest in RDB. RDB forwarded the executed Form
870-L(AD), which applied to the 1983 and 1984 taxable years, to
Redding, who forwarded the document to respondent.
On May 6, 1991, Redding delivered to Palka a letter dated
May 6, 1991. The relevant portion of the letter states:
Dear Mr. Palka:
Attached are separate envelopes containing
settlement acceptances for:
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