- 9 - 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 "TaxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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