5 * of the form entitled "Taxpayer(s) name(s), address and zip code." * * * * * * * * * * Second, sign the form twice in the spaces entitled "Signature of Taxpayer" and set forth the date you signed the agreement. * * * * * * * * * * Please note that you are not obligated to accept the above described settlement. After you have signed and transmitted the enclosed forms, however, you will not be able to retract your acceptance of the settlement offer. * * * * * * * * * * After we receive the executed Form 870-L(AD) * * * the form will be reviewed and executed by the Internal Revenue Service. The settlement is not final until the enclosed forms are signed by a representative of the Internal Revenue Service. The September 25th letter also set forth the address to which the completed forms should be mailed. The Form 870-L(AD) contains the following language: "the undersigned offers to enter into a settlement agreement"; "This offer is subject to acceptance for the Commissioner"; "Unless and until it is accepted, it will have no force or effect"; "If this offer is accepted for the Commissioner"; and "Date accepted for Commissioner". In November 1990 at Fensterheim's law offices, Fensterheim met with Goldbas on a matter unrelated to these cases. When the meeting ended, Fensterheim and Goldbas met privately to discuss Fensterheim's Transpac partnerships. The two met for about 30Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011