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individual limited partners. If an individual limited partner
chose to accept the settlement, the settlement letter would go to
the Ogden Service Center (OSC), which in turn, would send the
letter to Salt Lake City for an associate chief to sign. Upon
approval, the letter would then be returned to the OSC for
processing and a copy would be sent to the Appeals Office.
During May 1996, Appeals Officer Thurston worked on preparing
FPAA's for those limited partners who chose not to accept the
settlement offer. On June 6, 1996, Appeals Officer Thurston
wrote an attachment to the FPAA package providing instruction to
the OSC on how to process the settlement offers.
On June 10, 1996, Appeals Officer Thurston and Appeals
Office Manager Cole signed and dated a Form 5402, Appeals
Transmittal Memorandum and Supporting Statement, documenting the
Office of Appeals' settlement offer and acknowledging that the
offer had been made to the individual partners of TLP. The Form
5402 recommended issuance of an FPAA for each limited partner who
had not accepted the settlement by returning a signed Form 870-
P(AD).
On June 13, 1996, respondent's Appeals Office record section
mailed the FPAA package to the OSC.7
7 During September 1995, all of the Fresno Service Center work
related to TEFRA partnerships, including TLP, was transferred to
the Ogden Service Center.
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