- 4 -
expressed respondent's willingness to settle both docketed and
nondocketed cases on the basis of an "at risk settlement" under
section 465. In closing, the letter stated: "This offer to
settle is open until September 28, 1990."
After receiving Mr. Long's letter, Mr. Faber contacted Mr.
Long to discuss whether investment tax credits would be allowed
under the settlement offer outlined in his letter. In response
to this query, Mr. Long followed up with a letter dated November
1, 1990, to Mr. Faber. This letter stated in relevant part:
By letter dated August 6, 1990, we extended an offer to
settle the above mentioned movie partnerships. We offered
to settle these cases on the basis of and[sic] I.R.C. [sec.]
465 "at risk" settlement. * * *
We originally requested that you accept, or reject, the
offer to settle by September 28, 1990. * * * Since we were
unable to respond to your question within a reasonable time
before the September 28, 1990, deadline, we advised you that
we would tender a subsequent offer to you which would
address the investment tax credit issue.
The purpose of this letter is to extend a new offer to
settle these cases on the basis of an "at risk" settlement
under I.R.C. [sec.] 465.
In closing, Mr. Long wrote: "This offer is open for fourty-
five[sic] days, after the date of this letter." Mr. Faber
rejected this settlement offer on behalf of the partners.
On December 2, 1991, respondent issued notices of final
partnership administrative adjustment (FPAA's)4 to the TMP,
4
The FPAA is the notice provided to affected taxpayer-
partners of respondent's final administrative adjustment for
specific partnership tax years. The FPAA is to the litigation of
(continued...)
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