8
Transpac partnership 1982-1 and the stipulated decision document
relating to Transpac partnership 1981-10 to Goldbas. Deshler
prepared a cover letter dated June 14, 1991, and she signed
Fensterheim's name on his behalf. The relevant portion of the
letter states:
Re: Asher and Deborah Fensterheim
Transpac Drilling Venture
1982-1
Tax Years 1982, 1983, and 1984
Dear Mr. Goldbas:
In accordance with our telephone conversation, I
am forwarding to you form 870-L(AD) Settlement
Agreement for Partnership Adjustments and Affected
Items, which has been signed by both Asher Fensterheim
and Deborah Fensterheim.
I also enclose four copis [sic] of the Stipulation
and Decision in the Tax Court case, Docket No. 9906-90,
which has likewise been signed by both Asher
Fensterheim and Deborah Fensterheim.
I would appreciate your calling me upon receipt of
the enclosed as I would like to discuss with you what
the next steps will be.
On June 14, 1991, Deshler mailed a package to Goldbas that
contained the following: (1) The cover letter dated June 14,
1991, signed on behalf of Fensterheim by Deshler; (2) an executed
Form 870-L(AD) related to Transpac partnership 1982-1 for the
taxable years 1982, 1983, and 1984, bearing Fensterheim's and his
wife's original signatures, together with the accompanying
Schedule of Adjustments; and (3) the stipulated decision for
Transpac partnership 1981-10 bearing Fensterheim's and his wife's
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