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Dear Ms. Rowland:
We have attempted, without success, to reach you by
telephone. We have signed the enclosed papers concerning
the settlement of the case with Barrister Books, but are
very confused about the figures that are on the enclosed
statements. When we made the original investment,
everything was legal, had been checked by the IRS and
attorneys and was approved as a valid investment. Now, the
tables have really turned! The last correspondence that we
had from you was in November, 1993, and it has taken a year
to respond to us. At that time we had forwarded to you
copies of checks, etc. that proved when we entered this
partnership. Why has it taken so long? Also, why has it
taken nearly 14 years to bring this case to this point? It
hardly seems fair to us that we should be penalized for
something that was legal in the first place, and then, 14
years later, becomes a tax problem and we are the ones that
bear the brunt of it.
We would appreciate any answers that you could give us.
On December 23, 1994, Rowland prepared, signed, and sent to
Becker an appeals transmittal and case memorandum which outlined
the terms of the settlement of petitioners’ case.
On January 13, 1995, Becker signed and approved the appeals
transmittal and case memorandum. That same day, Becker wrote to
petitioners as follows:
Dear Mr. & Mrs. Goettee:
The proposed settlement you reached with the Appeals
Officer, as reflected in the stipulation-decision document,
has been approved. We have forwarded the stipulation you
signed to District Counsel for filing with the United States
Tax Court.
The Tax Court will notify you of entry of the stipulation.
If there is any amount due as a result of this settlement,
you will be billed by the service center.
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