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 15

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          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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