7
computation before you executed the consent form which
will result in the settlement of your Transpac Drilling
Venture losses. These computations account for the
matters raised in your accountant's letter of March 14,
1991. Your accountant agreed with our computation of
the tax deficiencies for the 1983 and 1984 years and
requested that we consider certain items that related
to the 1982 year that were allegedly not considered in
the original computations that we submitted to you on
February 13, 1991. Accordingly, as agreed, you will
execute the agreements relating to the assessment for
the 1982 through 1985 tax years as soon as possible.
In light of the status of the current partnership
actions, we will provide 30 additional days for the
execution of the Form 870-L agreements that we have
provided in order to resolve the tax deficiencies
relating to Transpac partnership items for the 1982
through 1985 years.
Milo reviewed the computations, revised them, and mailed the
revised computations to Goldbas in a letter dated June 3, 1991.
After unsuccessful attempts to reach Goldbas by phone,
Fensterheim sent a letter to Goldbas via Federal Express dated
June 7, 1991, stating that he wanted to discuss the various
settlement documents. After receiving Fensterheim's letter,
Goldbas called Fensterheim, and they discussed the various
documents.
On June 10, 1991, Fensterheim and his wife executed the Form
870-L(AD) for Transpac partnership 1982-1. They also executed
the stipulated decision for Transpac partnership 1981-10.
Fensterheim gave the executed documents to his secretary, Apryl
Deshler (Deshler).
On June 14, 1991, Fensterheim was in Boston, and he called
Deshler and instructed her to send the Form 870-L(AD) for
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