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 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 and            

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