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On March 8, 1994, Appeals Officer Koniarski sent the Blue Gem TMP
another letter, requesting the TMP contact him to discuss
potential settlement of the Blue Gem case. The March 8, 1994,
letter was substantially similar to Mr. Koniarski’s earlier May
8, 1992, letter to the TMP.
During the period from March 14, 1990, through October 22,
1995, Appeals Officer Koniarski also attempted to telephone the
Blue Gem TMP. The dates of the telephone calls do not appear in
the record. The Blue Gem TMP did not respond to any of the
contacts made by Mr. Koniarski. With the exception of the
letters and telephone calls described above, Mr. Koniarski did
not work actively on the Blue Gem case during this period.
Instead, he worked on other unrelated cases.
October 23, 1995, Through August 1997
On October 23, 1995, Appeals Officer Koniarski began
preparing FPAA’s and related documents with respect to Blue Gem’s
1982 and 1983 partnership returns. In addition, Mr. Koniarski
prepared a supporting statement recommending the issuance of the
proposed FPAA and submitted it to supervisory personnel in the
New York City Appeals Office. In his supporting statement, Mr.
Koniarski recommended that most of the adjustments and penalties
proposed by the examining agent with respect to Blue Gem and its
partners should be included in the FPAA. He recommended,
however, that the substantial understatement penalty proposed by
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