- 20 - Attached to Mr. Denny's letter is a copy of the letter Mr. Caldwell had sent to Mr. Norstrud, quoted above. The date of Mr. Denny's letter, June 5, 1991, is 128 days after the date on which respondent issued the notice of FPAA, January 28, 1991. By letter dated June 13, 1991, Mr. Norstrud responded to Mr. Denny. Mr. Norstrud's letter states as follows: Dear Mr. Denny: In response to your letter dated June 5, 1991, the partnership referenced (Wayne H. Caldwell Escrow) has had a final determination made on the case. The FPAA (final part- nership administrative adjustment) has been issued. The tax matters partner has 90 days from the issuance date of the FPAA to file a petition with the Tax Court, District Court or Court of Claims if the proposed adjustments are not agreed to. If no petition is filed within the first 90 days the notice partners then have 60 days in which to file a petition with one of the Courts. If no petition is filed the case will be defaulted 150 days after issuance of the FPAA. At this time the processes will begin to have any applicable adjustments made to the partners [sic] returns. If you have additional questions regarding the partner- ship return you should contact the tax matters partner, Mr. Caldwell. Sincerely, /s/ D.V. Norstrud Daniel V. Norstrud Appeals Officer Another partner, Mr. Gene A. Nickerson, also wrote to respondent in response to the notice of FPAA.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011