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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 instructions
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