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 10

          Fensterheim's partnership items in Transpac partnership 1982-15             
          or Transpac partnership 1982-21.                                            
               Respondent has no record of having received from Fensterheim           
          in 1991 an executed Form 870-L(AD) for either Transpac                      
          partnership 1982-15 or Transpac partnership 1982-21.                        
               In 1991 and 1992, respondent's Albany District Counsel                 
          maintained settlement logs that constituted a record of documents           
          pursuant to Rule 248(c) received from Internal Revenue service              
          centers.  During those years, respondent's Albany District                  
          Counsel did not maintain a log reflecting:  (1) Communications              
          from taxpayers about possible settlements; (2) receipt of Forms             
          870-L(AD) submitted by taxpayers; or (3) Forms 870-L(AD) received           
          from taxpayers by respondent's service centers.                             
               On March 11, 1992, respondent attempted without success to             
          deliver to Fensterheim informal discovery requests for Transpac             
          partnership 1982-21.  Respondent delivered these documents to               
          Fensterheim on June 23, 1992.                                               
               In a letter to Goldbas dated July 30, 1992, Fensterheim                
          stated that he had settled the various Transpac partnerships and            
          had paid the deficiencies.                                                  
               In a letter to Fensterheim dated August 28, 1992, Rosalyn C.           
          Shaughnessy (Shaughnessy), a paralegal in respondent's Albany               
          District Counsel office, advised Fensterheim that respondent's              
          records indicated that Fensterheim and respondent had settled               

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