15
contends that respondent somehow lost the Forms 870-L(AD) for
Transpac partnerships 1982-15 and 1982-21. Fensterheim concludes
that respondent's failure to process the Forms 870-L(AD) for
Transpac partnership 1982-15, and 1982-21 does not affect the
validity of the settlements. Respondent contends that the
package mailed by Deshler did not contain executed Forms 870-
L(AD) for Transpac partnerships 1982-15 and 1982-21.
Fensterheim has not shown that the package mailed by Deshler
contained executed Forms 870-L(AD) for Transpac partnerships
1982-15 and 1982-21. The cover letter dated June 14, 1991,
signed by Deshler on behalf of Fensterheim contains the following
caption:
Re: Asher and Deborah Fensterheim
Transpac Drilling Venture
1982-1
Tax Years 1982, 1983, and 1984
The body of that letter states "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." The caption and the quoted sentence
refer to a single Form 870-L(AD), which supports respondent's
argument that the package mailed by Deshler did not contain Forms
870-L(AD) for Transpac partnerships 1982-15 and 1982-21. The
signed stipulated decision for the already settled Transpac
partnership 1981-10 was also forwarded with this letter. The
signed stipulated decision for Transpac partnership 1981-10 was
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