Seymour and Beatrice Leffert - Page 7




                                        - 7 -                                         
               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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