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 settledPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011