Seymour and Beatrice Leffert - Page 6




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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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