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settlement terms for any Arbitrage Management partnership in which
the petitioner invested for all partnership years." (Emphasis
added.) The January 15, 1988, letter essentially covered taxpayers
who had only docketed cases as well as taxpayers who had both
docketed and nondocketed cases. Ms. Kaplan included with this
letter a copy of a letter from Mr. Nolan to Mr. Kletnick, dated
December 29, 1987, that describes the blanket settlement offer that
the partners accepted.
On January 21, 1988, Mr. Kletnick sent the Court a letter that
states: "Enclosed herewith are copies of listings of cases
forwarded to this office reflecting acceptance of the Service's
settlement offer." Petitioner's name and 1978 docket number are
included on that list. The January 21, 1988, letter was signed by
Mr. Kletnick on behalf of Agatha L. Vorsanger, Regional Counsel.
On February 25, 1988, Messrs. Kletnick and Nolan and Ms.
Kaplan attended another pretrial conference before the Court. At
that conference, Mr. Nolan stated that "we were able to reach a
basis of settlement with Mr. Kletnick, and we have communicated
that to all of the partners in the Arbitrage Management
partnerships." The parties advised the Court that they had settled
all or virtually all of the Arbitrage Management partnership cases,
and that they believed it unlikely that they would require a trial.
Messrs. Nolan and Janow and Ms. Kaplan understood that their jobs
were done and asked to be relieved of their responsibilities as
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