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 wasPage: 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