First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 7

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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               After said date it is withdrawn.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                

                    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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