- 8 - pocket cash and have deemed that settlement inappropriate. Based on analysis of the facts in the case as well as a review of the relevant court cases, I have decided to maintain the position that a full concession of all losses claimed by the partnership is warranted. The one area that I may be able to offer a concession is regarding the assertion of the Section 6661 penalty.[5] If you have any additional information to submit or would like to discuss this matter further, please contact me at the above number. Mr. Leffert has no record of receiving this letter. No conference between Appeals Officer Koniarski and the Blue Gem TMP regarding the Blue Gem case was held on March 13, 1990. March 14, 1990, Through October 22, 1995 After March 13, 1990, Appeals Officer Koniarski made several unsuccessful attempts to contact the Blue Gem TMP to schedule a conference. On May 8, 1992, Appeals Officer Koniarski sent a letter to the Blue Gem TMP requesting that the TMP contact him to discuss potential settlement of the Blue Gem case. The May 8, 1992, letter stated, in pertinent part: I have made several unsuccessful attempts to contact you regarding the above-named partnership. I have scheduled several appointments which you have not appeared as well as you have not returned numerous telephone calls. In order that we may consider a potential settlement of this case, it is necessary that we hold a conference in order to explore potential settlements. Please contact me at the address and telephone number shown above. 5During the examination, the revenue agent, among other things, had learned that, contrary to what had been represented in the Blue Gem offering materials, the mining geologist whose report was included in those materials had not actually visited the partnership’s mining property.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011