- 9 -
until August 12, 1993, when she wrote a letter to Mr. Reising
addressing his arguments.
After trading several telephone messages, on September 10,
1993, and again on September 16, 1993, Appeals Officer Thurston
and Mr. Reising spoke by telephone. By that time, discussions
had switched from the substance of the R&D issue to how
individual limited partners would be affected by the R&D loss
disallowance. Specifically, Mr. Reising was concerned about the
treatment of limited partners who sold their partnership
interests and reported gains after 1983 and 1984. After the
September 1993 telephone discussions, Appeals Officer Thurston
and Janet Spaulding, an Appeals TEFRA coordinator, worked on
formulating a settlement offer for TLP. Appeals Officer Thurston
attempted to accommodate Mr. Reising's request that separate
settlements be undertaken for the individual limited partners who
sold their interests; however, she and Appeals Coordinator
Spaulding later determined that separate settlements for those
partners would be impractical.
From September 17, 1993, through April 21, 1994, Appeals
Officer Thurston was still working with Appeals Coordinator
Spaulding to see if they could address the concerns of limited
partners who wanted a separately computed settlement. They
discussed the matter with their supervisors but did not prepare
any specific forms or documents. On April 22, 1994, Appeals
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