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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After said date it is withdrawn.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withdrawn.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).
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