- 25 - the limited partners on August 14, 1995, it was necessary to wait several months to see how many partners would accept the offer before respondent could send FPAA's to the limited partners who rejected the settlement. At that point, after the settlement letters were mailed, the speed at which the matter was to be closed was up to the partners. The Geises never signed a Form 870-P(AD), and respondent did not receive the Jacobses' Form 870- P(AD) until July 11, 1996. From May until July 1996, when respondent sent the FPAA's to petitioners, Appeals Officer Thurston prepared the documents to be included in the FPAA package. On the basis of the foregoing, we conclude that there were no errors or delays in the performance of ministerial acts by respondent's officers or employees during that period. Accordingly, we uphold respondent's final determination not to abate interest from April 22, 1994, through July 8, 1996. To reflect the foregoing, Decisions will be entered abating interest for the period of time stated herein.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Last modified: May 25, 2011