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 11

          Transpac partnership 1982-1 but not Transpac partnerships 1982-15           
          and 1982-21.                                                                
               In a letter to Shaughnessy dated September 9, 1992,                    
          Fensterheim stated that he had settled his interests in each                
          Transpac partnership, 1982-1, 1982-15, and 1982-21.  Fensterheim            
          enclosed with his letter copies of three Forms 870-L(AD), one for           
          each Transpac partnership, 1982-1, 1982-15, and 1982-21.                    
          Fensterheim's and his wife's signatures appeared on each of the             
          Forms 870-L(AD), but there were no signatures by respondent's               
          authorized representative.                                                  
               In a letter to Fensterheim dated October 13, 1992, Goldbas             
          informed Fensterheim that duplicate settlement packages for the             
          Transpac partnerships 1982-15 and 1982-21 would be sent to him              
          and that he should execute and return them to the Andover Service           
          Center.  Fensterheim did not execute these duplicate settlement             
               Under the TEFRA provisions, the tax treatment of partnership           
          items is decided at the partnership level in a unified                      
          partnership proceeding rather than separate proceedings for each            
          partner, Boyd v. Commissioner, 101 T.C. 365, 369 (1993), and                
          "affected items", items affected by the treatment of partnership            
          items (e.g. certain additions to tax), only can be assessed                 
          following the conclusion of the partnership proceeding.  See sec.           
          6225(a); Maxwell v. Commissioner, 87 T.C. 783, 791 n.6 (1986).              

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