- 146 -
I.R.C. Sections
Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2) 6621(c)
1979 -0- N/A -0- N/A -0-
1980 $15,000.00 N/A N/A N/A -0-
1981 $15,000.00 -0- -0- -0- -0-
In order to expedite the closing of these cases,
petitioners, through counsel, have executed waivers of
the limitations contained in I.R.C. � 6213(a), copies of
which are included in the files. Immediate processing
of the assessments are [sic] therefore appropriate.
If you have any questions regarding the processing
of this matter, pleased contact me at (808) 541-3350.
Shortly after receiving this memorandum, Mr. Li called Gary
Lipetzky (Mr. Lipetzky), an Appeals officer in Honolulu, who had
begun to gather information about the Bauspar program.
Mr. Lipetzky informed Mr. Li that he was the key Appeals officer
on the Bauspar program and that he had not formulated any
settlement offer for that program.
Mr. Li subsequently contacted his supervisor, Ron Wise
(Mr. Wise), Assistant Chief of Appeals in San Francisco, about
Mr. Sims' request. On May 22, 1992, Mr. Wise talked to Mr. Sims
about the Thompson cases. Mr. Sims told Mr. Wise that the
Thompsons had been selected as Kersting test cases, the Thompsons
had their own attorney, Mr. Kersting had threatened to sue the
Thompsons, Mr. Kersting had denied the Thompsons the return
on one of their investments, and Mr. Kersting considered
Mr. Thompson to be a renegade. Mr. Sims told Mr. Wise that he
and Mr. Thompson had worked out an informal arrangement that
the Thompsons would receive the better of the Tax Court decision
or the best settlement allowed to other Kersting program
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