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received no immediate response. A letter dated May 7, 1992, from
Coopers & Lybrand to a CIGNA vice president states that
settlements were still being entered into between the IRS and
taxpayers with docketed cases.
The IRS revenue agent assigned to audit Madison Leasing for
the taxable years 1983 through 1987 completed his examination
with respect to the first year on March 29, 1988, and with
respect to the final year on April 2, 1991. On January 28, 1993,
a proposed notice of final partnership administrative adjustment
(FPAA) pertaining to Madison Leasing for taxable years 1983
through 1987 was completed and submitted for approval to IRS
Regional Counsel. The finalized FPAA was issued on April 26,
1993. On July 19, 1993, a petition was filed in this Court
seeking review of respondent’s determinations made in the FPAA.
A decision was entered in that case by the Court upon
respondent’s motion on July 28, 2000.
The Madison Leasing examination was assigned to Appeals
officer Marco Minervini in October 1993. At that time, Mr.
Minervini was instructed to offer a settlement to the partners of
four partnerships making up Madison Leasing, including Green
Leasing. In addition to Madison Leasing, Mr. Minervini was
working on other Klineman-related partnerships which altogether
comprised more than 1,000 individual partners. Over the ensuing
months, Mr. Minervini worked on the settlement package fairly
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