- 9 - lead counsel. The Court then discharged them from their responsibilities as lead counsel. A letter from Mr. Berman to Ms. Kaplan dated April 21, 1988, states: Enclosed please find a copy of an Internal Revenue Service Memorandum, dated April 1, 1988, concerning the Arbitrage Management ("AMIC") settlement position. Mr. Kletnick has agreed that you or any taxpayer who invested through AMIC may use this memo when attempting to have an Arbitrage Management statutory notice rescinded. The attached Internal Revenue Memorandum, dated April 1, 1988, sent to all IRS offices from Regional Counsel, North Atlantic Region (Ms. Vorsanger), states in pertinent part: We have received authorization to disseminate settlement guidelines with respect to Arbitrage Management Investment Company cases. The basic agreement is that the taxpayers are entitled to 20 percent of the tax stake, or cash + 15 percent if greater. The Service is entitled to 80 percent. A proper allocation by year is required. Within this basic agreement, we have devised the methodology, outlined below, which is different for individual investor and partnership case. * * * * * * * Penalties described in I.R.C. Sections 6653, 6659 will not be imposed. E. Implementation of the Settlements Although the parties had settled the issue of the deductibility of the Arbitrage Management losses, the settlements still needed to be implemented. Under the settlements, most taxpayers had deficiencies in earlier years and overpayments in later years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011