17 Fensterheim should have been well aware that he had not settled Transpac partnerships 1982-15 and 1982-21. In October 1991, respondent served Notices of Settlement on Fensterheim that indicated a settlement of all partnership items related to Fensterheim's interests in Transpac partnership 1982-1. Fensterheim also received a copy of the Form 870-L(AD) related to Transpac partnership 1982-1 that had been countersigned by respondent's authorized representative. Fensterheim received no such Notices of Settlement or Forms 870-L(AD) related to Transpac partnerships 1982-15 and 1982-21, and Fensterheim never inquired as to whether these documents would be forthcoming. Respondent's authorized representative countersigned the Form 870-L(AD) for Transpac partnership 1982-1 on July 22, 1991. Fensterheim was aware that respondent had 1 year from the date of settlement to assess his partnership liabilities. We do not consider it a coincidence that Fensterheim's letter of July 30, 1992, to Goldbas was the first indication that Fensterheim considered his interests in Transpac partnerships 1982-15 and 1982-21 settled. We conclude that the package mailed by Deshler on June 14, 1991, did not contain executed Forms 870-L(AD) for Transpac partnerships 1982-15 and 1982-21. Fensterheim next argues that the copies of the Forms 870- L(AD) for Transpac partnerships 1982-15 and 1982-21 that he mailed to respondent on September 9, 1992, served to "ratify andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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