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remittance is hereby stated to be a deposit in the nature of
a cash bond.
By letter dated March 21, 1994, Carol M. Landy, Director of the
Internal Revenue Service Center in Holtsville, wrote to
acknowledge receipt of Mr. Newman's payment "as a cash bond for
payment of an amount that may be assessed later".
Prompted by an order of this Court dated June 29, 1994,5 Mr.
Newman wrote a letter dated July 14, 1994, to Maurice S. Stein of
the IRS Appeals Office in New York City. The letter stated in
pertinent part:
As you can see from the attached correspondence dated
February 1, 1994 with the Service, I have elected to accept
the Settlement offered by the Service to the limited
partners and have deposited the sum of $43,500 with the
Service.
Please (i) confirm to me that your records show that I have
accepted the settlement and (ii) advise me what further
steps I should take with respect to the settlement position
that is referred to in the Order.
On August 31, 1994, the IRS Regional Director of Appeals
forwarded a settlement package to Mr. Newman. The enclosures set
forth respondent's settlement position and invited Mr. Newman to
submit an offer by completing an enclosed Form 870-P(AD) within
30 days of the date of the letter. The letter also stated that
questions could be directed to the IRS contact person Pamela
Stueber at the Holtsville Internal Revenue Service Center. By
5
On June 29, 1994, this Court issued an order requiring
that all partners in Cinema '85 appear at a pretrial hearing in
New York set for September 22, 1994, unless a basis of settlement
had been reached with respondent.
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