Greenberg Brothers Partnership #12, a.k.a. Lone Wolf McQuade Associates, and Richard M. Greenberg, Tax Matters Partner - Page 6

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                    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               After said date it is withdrawn.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.  Mr. Faber was of the opinion              
          that during this time there were continuing settlement                      
          negotiations going on that may have produced better terms.                  
          Shortly thereafter, Mr. Faber withdrew as counsel of record.                
               In late 1992, George J. Noumair (Mr. Noumair) began                    
          settlement discussions with Mr. Long on behalf of partners who              
          wanted to settle.  Pursuant to inquiries from Mr. Noumair                   
          concerning settlement, Mr. Long wrote to Mr. Noumair on April 22,           
          1993, with regard to Lone Wolf.  The letter stated that                     
                    A number of the limited partners have contacted the               
               respondent and indicated their interest in accepting                   
               respondent's settlement offer.  We are, therefore, going to            
               have the Service Center make the settlement offer directly             
               to the limited partners, so that those interested in                   
               settling can close out their interest in this partnership.             
          In the course of ongoing discussions with Mr. Long, Mr. Noumair             
          indicated that he would survey the partners in order to ascertain           
          who desired to settle.  On June 24, 1993, Mr. Noumair sent a                
          memorandum to the Lone Wolf limited partners in which he stated:            
          "If you wish to 'opt out' and settle individually at this time,             







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