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Associates. Neither the Blue Gem TMP nor any other notice
partner filed a protest. On October 18, 1988, the protest was
forwarded to the Manhattan District Office of the IRS for
consideration.
December 31, 1988, Through March 13, 1990
On March 30, 1989, a case manager in the Manhattan District
Office reviewed the protest and concluded that the protest was
acceptable for processing by the IRS’s Appeals Office in New York
City. On June 5, 1989, the Blue Gem case was assigned to Appeals
Officer Stephen Koniarski.
On June 20, 1989, Appeals Officer Koniarski sent a letter to
the Blue Gem TMP advising him that the Blue Gem case had been
referred to the New York City Appeals Office for consideration.
A copy of the letter was not sent to either 7201 Associates or to
Mr. Leffert. In the letter, Mr. Koniarski also stated he would
contact the Blue Gem TMP by July 5, 1989, to schedule a mutually
convenient Appeals conference regarding the case.
On June 20, 1989, Appeals Officer Koniarski called Mr. Kratz
to discuss the Blue Gem case. Mr. Kratz, however, advised Mr.
Koniarski he was no longer representing Blue Gem. On July 5,
1989, Appeals Officer Koniarski called Mr. Leffert and advised
him that the Blue Gem case had been referred to the New York City
Appeals Office for consideration.
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