- 7 - executed by the partners. After the cash is used up the amount at risk is zero. However, to the extent the partnership earns net income in later years, the amount at risk will be increased in accordance with I.R.C. [sec.] 465. For the purposes of settlement the respondent will concede all additions to tax, but respondent will not concede additional interest under I.R.C. [sec.] 6621(c). You have thirty days to accept this settlement offer. After said date it is withdrawn. The settlement offer made to Mr. Faber was intended as an offer to settle at the partnership level and was not intended to be made to the individual partners. By letter dated September 14, 1992, however, Mr. Long wrote to Mr. Redding regarding docket No. 17752-85, indicating that respondent was conceding the deficiency asserted for the 1982 partnership taxable year.8 Enclosed was a document titled "Stipulation of Settlement" setting forth respondent's concession of the 1982 year. The letter also stated in pertinent part: We are willing to settle the First Blood Associates issue for years after 1982 on the basis of an "at risk" settlement under I.R.C. [sec.] 465. * * * * * * * * * * Please advise me within the next thirty days if you wish to accept the settlement offer to settle First Blood Associates for all years. If we have not heard from you in thirty days you should consider the settlement offer as withdrawn. 8 As of the date of the September 14, 1992, letter the Goodwins were also parties to the cases at docket Nos. 623-92, 13014-92, and 15641-92 pursuant to sec. 6226(c)(1) and Rule 247(a). The Goodwins subsequently elected to participate in these proceedings pursuant to sec. 6226(c)(2) and Rule 245(b).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011