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 aPage: 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