Transpac Drilling Venture 1982-21, Asher Fensterheim, Charles L. Pincus, Thomas D. Callahan, Donald W. Dvorak, and Thomas J. Williams, Partners Other Than The Tax Matters Partner, et al. - Page 4

          had assigned Michael Goldbas (Goldbas) as the lead attorney on              
          that project.  The project encompassed over 2,000 partners, and             
          Goldbas was responsible for the administration and litigation of            
          the Transpac project.                                                       
               Respondent mailed the tax matters partners of Transpac                 
          partnerships 1982-15 and 1982-21 Notices of Final Partnership               
          Administrative Adjustments that set forth adjustments determined            
          by respondent for the taxable years 1982, 1983, and 1984.                   
               In a letter dated September 25, 1990 (September 25th                   
          letter), respondent mailed Fensterheim a separate Settlement                
          Agreement for Partnership Adjustments and Affected Items (Form              
          870-L(AD)) for each Transpac partnership, 1982-1, 1982-15 and               
          1982-21.  Relevant portions of the September 25th letter state:             
                    In re:    Settlement of Tax Matters                               
                              Relating to Transpac                                    
                              Drilling Venture                                        
                    Dear Transpac Investor:                                           
                    You are probably aware that the Service has                       
               developed a settlement proposal with respect to matters                
               relating to the disallowance of the losses (and                        
               credits) you reported from your Transpac Drilling                      
               Venture.  The pending settlement offer is that you                     
               concede the full disallowance of all reported                          
               partnership losses (and credits) and the Government                    
               will concede all penalty issues.  The interest on the                  
               tax deficiencies resulting from this settlement will                   
               run at 120% of the prevailing rate pursuant to I.R.C. �                
               *        *        *        *        *        *        *                
                    In order to process the above described settlement                
               you must complete the enclosed form 870-L(AD) * * * in                 
               the following manner:  First, complete the section * *                 

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