- 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.
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