- 6 -
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.
After the filing of the petitions in docket Nos. 623-92,
13014-92, and 15641-92 Mr. Long again wrote to Mr. Faber on the
subject of the Greenberg Brothers project, listing First Blood in
the subject portion of the letter. The letter dated September 9,
1992, stated:
We are offering to settle the above referenced movie tax
shelters on the basis of an "at risk" settlement under
I.R.C. [sec.] 465. For purposes of the settlement taxpayers
are considered at risk to the extent of their initial cash
investment in the movie, with no amounts allowed for notes
executed by the partnership, or the assumption agreement
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