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 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                       
               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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