- 14 - was necessary to effect a settlement of a partner's various liabilities.8 Mr. Newman may have attempted to accept an offer from respondent to settle the case. It is clear, however, that all the parties directly connected with the settlement negotiations understood that to effectuate the settlement either a closing agreement or a Form 870 had to be executed. It is also clear that, although the forms were sent to Mr. Newman, he never executed them, and, consequently, there was no settlement of his case.9 To reflect the foregoing, An appropriate order will be issued denying Mr. Newman's motion to dismiss for lack of jurisdiction. 8 Whether this opinion was correct or not is beside the point. 9 We leave for a subsequent opinion the question whether Mr. Newman may be entitled to consistent settlement terms pursuant to sec. 6224(c)(2) and sec. 301.6224(c)-3T, Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6787 (Mar. 5, 1987).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
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