John G. Goettee, Jr. and Marian Goettee - Page 22

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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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