Wayne Caldwell Escrow Partnership, Roy Dimon, John and Mary Schuenemann, Joseph and Louise O'Neal, Charles and Lovetta Niven, Chalton and Cynthia Thomas, Partners Other Than the Tax Matters Partner - Page 9

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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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