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 13

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             "Tax Matters Partner".  Agent Schieck never received a                   
             response to the letters he sent in July 1989.                            
                  Sometime in 1989, Mr. Denny received a telephone call               
             from one of respondent's agents.  The agent said that                    
             Mr. Denny was the tax matters partner because he held the                
             largest profits interest in the partnership.  However, no                
             action was taken by respondent, Mr. Denny, or any other                  
             member of the partnership to formally designate Mr. Denny                
             as tax matters partner.                                                  
                  In August 1989, Agent Schieck scheduled a conference                
             to administratively close the partnership's case.                        
             Mr. Caldwell appeared at the conference and was                          
             accompanied by Mr. Raymond Woody, another partner.  During               
             the conference, Mr. Caldwell asked to see the credentials                
             and delegation orders of respondent's representatives and                
             was otherwise uncooperative.  Because Mr. Caldwell had not               
             brought the documentation that Agent Schieck had requested,              
             the meeting was quickly concluded.                                       
                  Sometime thereafter, the case was returned to                       
             respondent's Appeals Office in Dallas, Texas, and                        
             Mr. Norstrud prepared a so-called FPAA package, a group                  
             of documents, including a notice of FPAA and an explanation              
             of adjustments, that are required under respondent's                     








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