Laurence L. and Patricia Jacobs - Page 11




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          April 1995, Appeals Officer Thurston, aided by Appeals                      
          Coordinator Spaulding, worked on an Appeals case memorandum and a           
          TEFRA settlement offer package.  The package included completing            
          Form 870-P(AD), Form 5402, Appeals settlement memorandum, Form              
          4605-A, and Form 886-Z(C).  Completing the settlement package was           
          time consuming.  The amount of time it took to complete the                 
          settlement package was compounded by problems with the networked            
          computer system and difficulties obtaining computer disks from              
          the examination group that were necessary to complete the                   
          settlement package.  Appeals Officer Thurston had to also                   
          organize Appeals personnel to perform computations for each of              
          the 125 to 135 limited partners.                                            
               On May 2, 1995, Appeals Officer Thurston spoke with Mr.                
          Knoke concerning how the settlement would work for those limited            
          partners who sold their partnership interests.  Between May and             
          June 1995, Appeals Officer Thurston completed the TEFRA                     
          settlement package.  On June 30, 1995, Appeals Officer Thurston             
          submitted the case to her manager, Janet Cole, for approval.  On            
          July 13, 1995, the Appeals Office forwarded a settlement package            
          to the FSC.  The transmittal letter instructed the FSC to issue             
          letters and agreement forms to the TLP partners.                            
               On August 14, 1995, the FSC mailed settlement letters to the           
          limited partners.  After issuance of the settlement letters, the            
          Internal Revenue Service (IRS) waited for responses from the                






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