- 10 - Arbitrage Management partners emphasized that they wanted respondent to establish a procedure whereby the IRS could process the deficiency and overpayment years at the same time, so that the taxpayers could pay a net amount. After the February 25, 1988, pretrial conference, Mr. Kletnick sent the Court quarterly status reports of the Arbitrage Management cases. The reports described the progress of the IRS in developing settlement implementation procedures regarding all tax years individuals invested in Arbitrage Management. For instance, an October 24, 1988, status report sent to the Court states in pertinent part: The settlement implementation procedures, with respect to individuals who were partners in TEFRA partnerships, are currently being considered by the Office of Chief Counsel in Washington, D.C. As you well know, the parties had agreed to resolve all of the years which were in dispute as a result of an individuals [sic] "investment" in AMIC. In many cases this involves settling a taxpayer's 1978 through 1987 years. It has been estimated by the Examination Division of the Internal Revenue Service that this settlement will affect over 800 partnerships and 9,000 individual tax returns. [Emphasis added.] Moreover, in a January 30, 1989, status report, the Court was notified that: "the settlement implementation procedures, with respect to individuals who were partners in TEFRA partnerships, have been approved and issued by the Office of Chief Counsel in Washington, D.C." The status reports did not suggest that the IRSPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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