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On October 26, 1989, Appeals Officer Koniarski sent letters
to all Blue Gem notice partners, including 7201 Associates,
scheduling an Appeals conference for November 16, 1989, and
advising the partners of their right to participate in the
proceedings. None of the notice partners responded to Mr.
Koniarski’s letters. Mr. Leffert has no record of receiving the
letter Mr. Koniarski sent to 7201 Associates.
On February 2, 1990, Appeals Officer Koniarski scheduled a
March 12, 1990, conference with Mr. Leffert to discuss a possible
settlement of the Blue Gem case. On March 1, 1990, Mr. Koniarski
sent a letter to the Blue Gem TMP, scheduling a March 13, 1990,
conference.
On March 12, 1990, Appeals Officer Koniarski and Mr. Leffert
attended the scheduled conference. At the conference, Mr.
Leffert proposed a “cash-out-of-pocket” settlement that would
have required the IRS to allow Mr. Leffert the partnership losses
claimed for 1982 and 1983 attributable to Blue Gem to the extent
of his actual cash investment. On March 13, 1990, Appeals
Officer Koniarski sent a letter to Mr. Leffert rejecting the
settlement proposal Mr. Leffert had submitted at their March 12,
1990, conference. Mr. Koniarski’s letter stated in pertinent
part:
Please find enclosed copy of Engineering Report
that you requested at our March 12, 1990 conference. I
have given consideration to your proposal for
settlement made at the conference based on out of
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