- 9 - Stipulation of Settlement referred to in Mr. Long's letter was returned. 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 instructionsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011