- 11 - was continuing to contemplate the preliminary question of whether to permit deductions for Arbitrage Management losses. Respondent's counsel and Arbitrage Management partners' counsel eventually agreed upon a form of closing agreement to settle the cases. A December 21, 1989, letter from Mr. Nolan to Mr. Kletnick states: I am writing to you on behalf of two groups of partners that retained Miller & Chevalier and Saltzman & Holloran to negotiate a settlement for their Tax Court cases. At long last, it is my pleasure to enclose with this letter a copy of the standard language for Form 906 closing agreements that we anticipate the Internal Revenue Service will offer to all of the partners in the following Arbitrage Management partnerships * * * * * * * It is our understanding that the attached language will be used to resolve the Arbitrage Management issues for all partners (whether or not they belong to one of the two groups we represent) and for all years (whether or not they are docketed in the Tax Court). * * * * * * * As you know, a Form 906 closing agreement is a final determination covering specific matters, and has no effect on matters that are not discussed in the language of the agreement. This is particularly important in this case because the settlement we reached for Arbitrage partners resolves the amount of taxable income, deductions, gains and losses from the Arbitrage partnerships for all taxable years (past, present and future). [Emphasis added.]Page: 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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