- 19 -
nership level regarding this matter so you would have that
information available if you would be responding to them.
If you desire this office to be of further assistance, or
service to you regarding this matter or any action that you may
wish to take with the IRS, please send any copies of correspon-
dence you have received from them any response you have made and
one hundred dollars ($100) to open your account, and we will
begin the research and will advise you of which course of action
we recommend and can be ready to assist you if you so desire.
Sincerely;
Wayne H. Caldwell
On June 5, 1991, Mr. Denny also wrote to Mr. Norstrud
regarding the notice of FPAA. Mr. Denny's letter states
that it was his understanding that the matter had been
closed on August 29, 1989, and that the period of
limitations had expired. Mr. Denny's letter states as
follows:
Mr. Dan Norstrud
Internal Revenue Service
1100 Commerce St
Dallas TX 75242
Re: Partnership, Wayne H. Caldwell, Escrow
Dear Mr. Norstrud:
It is my understanding this matter was closed as of
August 29, 1989. The tax return of 1983 was in question,
but I am sure the statute of limitations has now expired.
I request that you send a letter of recission to the Tax
Matters Partner, Mr. Wayne H. Caldwell and to me.
I have attached a copy of Mr. Caldwell's letter to you.
Sincerely
Bill R. Denny
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