- 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.
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