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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