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respondent and asking what further steps would be necessary to
effect a settlement.
By letter dated November 30, 1993, Mr. Noumair wrote to Mr.
Long with regard to partners in Cinema '85 and seven other
Greenberg Brothers partnerships who desired "to accept the IRS
settlement offer and opt out of the TEFRA proceeding". The
letter also stated: "I would appreciate it if, with respect to
the partners who wish to opt out, you would send to me the
documents you will require to be executed for filing in the Tax
Court." Attached to the letter was a separate list for each
partnership, indicating the names and interests of the partners
wishing to opt out of the TEFRA proceeding; Mr. Newman is listed
on an attachment titled "Limited Partners in Cinema '85 Limited
Partnership Who Want to Opt Out and Settle as of 11/30/93".
According to Mr. Long, at that time, settlement would be
"achieved" by signing a Form 870 or entering into a closing
agreement. Mr. Faber also had understood "that there would be
some documents that would have to be executed to implement * * *
[a settlement]."
On February 1, 1994, Mr. Newman wrote to the Internal
Revenue Service (IRS) in Holtsville, New York, stating:
I am one of the limited partners who has opted to accept the
Internal Revenue Service's settlement offer.
I wish to make an immediate remittance to the Internal
Revenue Service of the settlement amount. * * * Enclosed is
my check in the amount of $43,500. * * * [T]he enclosed
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