6
minutes and discussed the September 25th letter, the forms that
Fensterheim received from respondent, and the procedure for
settling Fensterheim's interests in the Transpac partnerships.
Sometime after the November 1990 meeting, Fensterheim asked
Goldbas what the deficiencies would be if Fensterheim agreed to
settle in each of the Transpac partnerships. In a letter to
Fensterheim dated February 13, 1991, Goldbas sent computations of
Fensterheim's tax deficiencies for the taxable years 1982 through
1985 based on the disallowance of losses and deductions from the
Transpac partnerships, 1982-1, 1982-15, and 1982-21. Fensterheim
asked his accountant, John Milo (Milo), to review the
computations.
Milo recalculated the tax deficiencies shown in Goldbas'
letter of February 13, 1991, and mailed the recalculated figures
to Goldbas in a letter dated March 14, 1991.
On May 10, 1991, Goldbas mailed Fensterheim a stipulated
decision for Transpac partnership 1981-10 and a revised
computation of the tax deficiencies for the years 1982 through
1985 based on the disallowance of losses and deductions from
Transpac partnerships 1982-1, 1982-15, and 1982-21. The relevant
portion of Goldbas' May 10, 1991, letter states:
Pursuant to your request we have computed the
deficiencies for the 1982, 1983, and 1984 years
resulting from the disallowance of Transpac Drilling
Venture losses. As you are aware, you are a petitioner
in the partnership actions that control the 1982, 1983,
and 1984 tax years relating to the Transpac Drilling
Ventures in which you are a partner. You wanted a
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