Seymour and Beatrice Leffert - Page 8




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               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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