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protest letter, Mr. Caldwell stated that he was appealing
on behalf of "Wayne H. Caldwell only".
On November 17, 1986, an Appeals officer in Dallas,
Texas, Mr. Dan Norstrud, sent a letter to Mr. Caldwell,
addressing him as "Tax Matters Partner". Mr. Norstrud's
letter states that if Mr. Caldwell was "not appealing the
adjustments to the partnership but some possible future
adjustment to your personal return", then "your appeal
is premature and based on the new TEFRA laws is
inappropriate." Mr. Norstrud's letter further informs
Mr. Caldwell that if he wished to appeal the proposed
adjustments on behalf of the partnership, then he must
supply the originals or copies of the documents that had
been requested during the examination. Mr. Norstrud's
letter warns Mr. Caldwell that if he did not respond and
provide the requested documents, "including a copy or
original of the asset (Laser Disk)", then a notice of FPAA
would be issued. Mr. Norstrud's letter also informs
Mr. Caldwell of the time limits for contesting a notice
of FPAA in court.
On December 3, 1986, Mr. Caldwell wrote to
Mr. Norstrud and referred to himself as the "Tax
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