First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 9

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          Stipulation of Settlement referred to in Mr. Long's letter was              
               Respondent received the October 14, 1992, letter on Monday,            
          October 19, 1992.  Neither Mr. Long nor any other representative            
          of respondent ever responded to Mr. Redding's request for                   
          confirmation of the timely receipt of the Goodwins' acceptance of           
          the settlement.                                                             
               In late 1992, Mr. George J. Noumair (Mr. Noumair) began                
          settlement discussions with Mr. Long.  Mr. Noumair also                     
          understood that other documents were needed to effectuate a                 
          settlement between the partners and respondent.  See Greenberg              
          Brothers Partnership #12, a.k.a. Lone Wolf McQuade Associates v.            
          Commissioner, T.C. Memo. 1998-198.                                          
               By letter dated November 15, 1994, Mr. Long wrote to the               
          Goodwins at Montgomery, Texas, offering to settle the instant               
          cases.  That letter stated, inter alia:                                     
               Your partnership liabilities are not settled until both you            
               and the IRS properly execute the enclosed closing agreement.           
                    *    *    *         *    *    *     *                             
                    If your case is settled, the IRS will calculate your              
               tax liabilities for the loss years.  You will have to file             
               amended tax returns (Forms 1040X) for the gain years to                
               offset losses suspended under the settlement against income            
               reported from the partnership.                                         
          Enclosed with the letter was a closing agreement (Form 906) that            
          set forth the basis of the at risk settlement.  On instructions             

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